Finding 1101574 (2023-009)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-02-28

AI Summary

  • Core Issue: The Organization lacks proper documentation for procurement processes, failing to meet federal requirements for both competitive and noncompetitive procurements.
  • Impacted Requirements: Non-compliance with 2 CFR §200.303 and §200.318, which mandate effective internal controls and detailed procurement records.
  • Recommended Follow-Up: Ensure the Organization retains adequate procurement documentation to comply with federal standards and internal policies.

Finding Text

Information on the federal program – All federal programs Criteria or specific requirement – According to 2 CFR §200.303, the non-federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Additionally, according to 2 CFR §200.318 Procurement standards, the non-federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Title 2, Subtitle A Chapter II Part 200 Subpart D 200.319 Procurement Standards. All procurement transactions for the acquisition of property or services required under a federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-federal entity must have written procedures for procurement transactions. These procedures must ensure that all solicitations: (1) Incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Such description must not, in competitive procurements, contain features which unduly restrict competition. The description may include a statement of the qualitative nature of the material, product or service to be procured and, when necessary, must set forth those minimum essential characteristics and standards to which it must conform if it is to satisfy its intended use. Noncompetitive procurements can only be awarded in accordance with §200.320(c). According to 2 CFR §200.320 Procurement Standards, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: 1. The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); 2. The item is available only from a single source; 3. The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; 4. The federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-federal entity; or 5. After solicitation of a number of sources, competition is determined inadequate. Condition – During the 2022 audit, the predecessor auditor determined that the Organization did not clearly document the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, for noncompetitive procurements, there was no documentation to support which of the five criteria was met to allow for the noncompetitive procurement. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that procurement requirements were adequately documented and retained. Effect or potential effect – Procurement records were insufficient to meet the requirements noted in the Criteria section above, as well as the Organization's internal procurement policy. Questioned costs – None Context – The predecessor auditor noted that several items selected for testing did not document the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, the predecessor auditor noted that several items selected for testing for noncompetitive procurements did not maintain documentation of which of the five criteria were met to allow for the noncompetitive procurement. Identification as a repeat finding, if applicable – Is a repeat finding (2022-007) Recommendation – We recommend the Organization retain sufficient procurement documentation to meet the requirements noted in the Criteria section above. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 525109 2023-004
    Significant Deficiency Repeat
  • 525110 2023-005
    Significant Deficiency
  • 525111 2023-005
    Significant Deficiency
  • 525112 2023-005
    Significant Deficiency
  • 525113 2023-005
    Significant Deficiency
  • 525114 2023-005
    Significant Deficiency
  • 525115 2023-006
    Significant Deficiency Repeat
  • 525116 2023-006
    Significant Deficiency Repeat
  • 525117 2023-006
    Significant Deficiency Repeat
  • 525118 2023-007
    Significant Deficiency
  • 525119 2023-007
    Significant Deficiency
  • 525120 2023-007
    Significant Deficiency
  • 525121 2023-007
    Significant Deficiency
  • 525122 2023-007
    Significant Deficiency
  • 525123 2023-008
    Significant Deficiency Repeat
  • 525124 2023-008
    Significant Deficiency Repeat
  • 525125 2023-008
    Significant Deficiency Repeat
  • 525126 2023-008
    Significant Deficiency Repeat
  • 525127 2023-008
    Significant Deficiency Repeat
  • 525128 2023-008
    Significant Deficiency Repeat
  • 525129 2023-008
    Significant Deficiency Repeat
  • 525130 2023-008
    Significant Deficiency Repeat
  • 525131 2023-009
    Significant Deficiency Repeat
  • 525132 2023-009
    Significant Deficiency Repeat
  • 525133 2023-009
    Significant Deficiency Repeat
  • 525134 2023-009
    Significant Deficiency Repeat
  • 525135 2023-009
    Significant Deficiency Repeat
  • 525136 2023-009
    Significant Deficiency Repeat
  • 525137 2023-009
    Significant Deficiency Repeat
  • 525138 2023-009
    Significant Deficiency Repeat
  • 1101551 2023-004
    Significant Deficiency Repeat
  • 1101552 2023-005
    Significant Deficiency
  • 1101553 2023-005
    Significant Deficiency
  • 1101554 2023-005
    Significant Deficiency
  • 1101555 2023-005
    Significant Deficiency
  • 1101556 2023-005
    Significant Deficiency
  • 1101557 2023-006
    Significant Deficiency Repeat
  • 1101558 2023-006
    Significant Deficiency Repeat
  • 1101559 2023-006
    Significant Deficiency Repeat
  • 1101560 2023-007
    Significant Deficiency
  • 1101561 2023-007
    Significant Deficiency
  • 1101562 2023-007
    Significant Deficiency
  • 1101563 2023-007
    Significant Deficiency
  • 1101564 2023-007
    Significant Deficiency
  • 1101565 2023-008
    Significant Deficiency Repeat
  • 1101566 2023-008
    Significant Deficiency Repeat
  • 1101567 2023-008
    Significant Deficiency Repeat
  • 1101568 2023-008
    Significant Deficiency Repeat
  • 1101569 2023-008
    Significant Deficiency Repeat
  • 1101570 2023-008
    Significant Deficiency Repeat
  • 1101571 2023-008
    Significant Deficiency Repeat
  • 1101572 2023-008
    Significant Deficiency Repeat
  • 1101573 2023-009
    Significant Deficiency Repeat
  • 1101575 2023-009
    Significant Deficiency Repeat
  • 1101576 2023-009
    Significant Deficiency Repeat
  • 1101577 2023-009
    Significant Deficiency Repeat
  • 1101578 2023-009
    Significant Deficiency Repeat
  • 1101579 2023-009
    Significant Deficiency Repeat
  • 1101580 2023-009
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $3.81M
93.676 Unaccompanied Children Program $2.87M
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $1.56M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $1.12M
93.926 Healthy Start Initiative $448,917
93.778 Medical Assistance Program $417,201
93.788 Opioid Str $382,004
93.268 Immunization Cooperative Agreements $372,292
93.526 Grants for Capital Development in Health Centers $362,489
93.310 Trans-Nih Research Support $221,357
93.994 Maternal and Child Health Services Block Grant to the States $114,183
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $86,396
93.217 Family Planning Services $86,353
93.185 Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects $66,886
93.527 Grants for New and Expanded Services Under the Health Center Program $64,286
93.110 Maternal and Child Health Federal Consolidated Programs $49,996
93.297 Teenage Pregnancy Prevention Program $33,250
93.426 The National Cardiovascular Health Program $28,715
16.588 Violence Against Women Formula Grants $17,131
93.917 Hiv Care Formula Grants $9,192
93.504 Family to Family Health Information Centers $7,127