Finding 1101213 (2024-005)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-02-27
Audit: 344160
Auditor: Marcum LLP

AI Summary

  • Core Issue: Missing documentation for vendor selection and initial debarment checks in procurement processes.
  • Impacted Requirements: Non-compliance with 2 CFR 200.318(i) regarding record-keeping for federal fund procurement.
  • Recommended Follow-Up: Emphasize the importance of consistent documentation practices to all procurement staff.

Finding Text

FINDING 2024-005 Procurement – Documentation FINDING TYPE Significant Deficiency in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 2 CFR 200.318(i), entities receiving federal funds are responsible for maintaining records that contain sufficient detail of the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractors selection or rejections, and the basis for the contract price. CONDITION AND CONTEXT We selected four procurements for testing. Out of these four, we noted one instance where the documentation of the rationale behind the vendor selection was not available. Management was able to explain to us why the vendor offered an appropriate mix of price and value to the Federal program, but the documentation of the decision was not able to be presented. Also, for one out of four tested items, a record of the initial debarment/suspension check was not able to be produced. Management was able to show us a master vendor database compliance screening that was run after this vendor had been selected. However, documentation of the initial check was not available. CAUSE The staff involved with these procurement decisions did not have a consistent process for maintaining documentation related to procurement decisions. EFFECT OR POTENTIAL EFFECT Without consistent documentation, there is a risk that procurement decisions will not be in compliance with the procurement requirements of the Uniform Guidance. REPEAT FINDING No. RECOMMENDATION We recommend that the organization reinforce to all personnel involved in procurement the importance of maintaining the required documentation for procurement decisions. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
16.034 Coronavirus Emergency Supplemental Funding Program $1.11M
93.150 Projects for Assistance in Transition From Homelessness (path) $272,728
93.217 Family Planning Services $246,704
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $198,791
14.239 Home Investment Partnerships Program $195,855
93.788 Opioid Str $110,302
93.959 Block Grants for Prevention and Treatment of Substance Abuse $105,560
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $100,414
93.778 Medical Assistance Program $83,859
93.958 Block Grants for Community Mental Health Services $78,989
93.493 Congressional Directives $78,684
93.526 Grants for Capital Development in Health Centers $68,623
14.218 Community Development Block Grants/entitlement Grants $67,549
21.027 Coronavirus State and Local Fiscal Recovery Funds $64,618
97.024 Emergency Food and Shelter National Board Program $53,249
14.231 Emergency Solutions Grant Program $48,540
14.267 Continuum of Care Program $32,440
93.994 Maternal and Child Health Services Block Grant to the States $32,088
93.527 Grants for New and Expanded Services Under the Health Center Program $24,926
93.667 Social Services Block Grant $21,678
93.569 Community Services Block Grant $15,812
93.914 Hiv Emergency Relief Project Grants $15,597
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $5,341