Finding Text
Health Center Program Cluster
Assistance Listing Nos. 93.224 and 93.527
U.S Department of Health and Human Services
Award Nos. 6 H80CS26514-10-02, 3 H8FCS40655-01-01, 4 H8GCS47538-01-01, 1 H8LCS50783-01-00
Criteria or Specific Requirement – Procurement – 45 CFR 75.329
Condition – The Organization did not follow its policy governing procurement requirements for the purchase of goods and services charged to federal awards.
Questioned Costs – Unknown
Context – A sample of one procurement was tested out of a population of six procurements totaling $605,943. The sample was not, and is not intended to be, statistically valid. The one procurement tested in the amount of $18,277 was not completed in accordance with the Organization’s procurement policy for vendor selection. The Organization’s procurement policy does not specify the micro-purchase limit and ongoing monitoring procedures of suspended and debarred vendors is not defined. Lastly, a sample of one vendor was tested out of a population of four vendors with contracts exceeding $25,000. The Organization did not retain documentation to support initial verification of vendor against the exclusions list.
Effect – Purchases were made that did not adhere to the Organization’s procurement policy.
Cause – The Organization did not comply with their federal procurement policy.
Identification as a repeat finding, if applicable – Not a repeat finding.
Recommendation – The Organization should review its procurement policy and ensure proper staff education on the policy is established. In addition, the Organization should review the policy on an annual basis to ensure it is consistent with Uniform Guidance.