Finding Text
2022-004
Missing documentation for procurement, suspension and debarment
93.341 Analyses, Research and Studies to Address the Impact of CMS Programs on American
Indian/Alaska Native (AI/AN) Beneficiaries and the Health Care System Serving these Beneficiaries
Audit Results:
Criteria: Per Uniform Guidance 2 CFR 200.318, any contracts procured with federal funds for over $10,000
should be obtained via a bidding process or documentation is required to show that the contractor is the
sole source for the services. In addition, the Organization should keep documentation to show that they
have verified that contractors are not suspended or debarred.
Condition: Bid or sole source documentation was missing for all five contracts that we selected for testing and
there was no documentation of the verification that the contractor was not suspended or debarred.
Questioned Costs: None
Context: It is important to determine that contractors used are eligible for work and that they have not been
suspended or debarred from performing work on projects supported by federal funds It is also
important to have full and open competition on contract work that is federally funded.
Effect:As a result, the Organization was missing documentation relating to the requirements for procurement,
suspension and debarment.
Cause:This is due to ineffective controls over the procurement process resulting from staff turnover.
Recommendation:
Auditors recommend that the Organization maintain all federal award documentation in a location where
all authorized personnel have access in order to ensure that it can always be located. We also
recommend that management create a process for procurement, including how bids are obtained and
maintained for proof of compliance with Uniform Guidance. Management should also establish
procedures for verifying that contractors are not suspended or debarred and a system for maintaining
this verification should be established. It is critical to maintain detailed documentation to ensure
compliance with Uniform Guidance requirements.
Views of Responsible Officials and Planned Corrective Actions:
Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan