Finding 1118269 (2024-003)

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Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: JHHS did not follow its own competitive bidding policy for two procurement transactions under the Healthy Start Initiative, violating federal requirements.
  • Impacted Requirements: Compliance with 2 CFR 200.318-320 and JHHS’s Competitive Bidding Policy, which mandates competitive bidding for purchases over $3,000.
  • Recommended Follow-Up: Implement a control process to ensure adherence to bidding requirements, maintain evidence of reviews, and provide training to relevant departments on federal and internal policies.

Finding Text

2024-003: Healthy Start Procurement Compliance and Control Deficiency Grantor: Department of Health and Human Services Program Title: Healthy Start Initiative Award Name: Healthy Start Initiative‐Eliminating Racial/Ethnic Disparities Award Number: H4927805 Assistance Listing Title: Healthy Start Initiative Assistance Listing Number: 93.926 Award Year: April 1, 2023 – August 31, 2024 Passthrough Entity: None Criteria Per 2 CFR 200.318-320, the auditee must maintain and use documented procedures for procurement transactions under a Federal award, including that procurement transactions must be conducted in a manner that provides full and open competition. Condition In accordance with JHHS’ Competitive Bidding Policy dated 5/5/2020, competitive bidding must be performed for all purchases under federal grants that exceed $3,000. JHHS’ policy has three exceptions: 1) emergency procurements, 2) compatible product requirements, which includes an option for the completion of a sole source justification memo, and 3) recently bid products/ services. For 2 of 2 procurement selections tested during the audit for the Healthy Start Initiative award, no evidence was found that competitive bidding procedures were followed in accordance with JHHS policy. Cause There was no control operating to ensure adherence to JHHS’s Competitive Bidding Policy on competitive bidding or sole source justification requirements prior to entering into a procurement transaction. Effect JHHS was not in compliance with federal requirements relating to procurement and two transactions were entered into without full and open competition. Questioned Costs There are no questioned costs associated with this finding. Recommendation JHHS should establish a control process to ensure that all required competitive bidding or sole source justification requirements are followed including review and approval prior to entering into procurement transactions, and evidence of such review and approval is maintained. JHHS should also ensure appropriate training and communication is shared with all departments responsible for managing federal grant programs to ensure adherence to federal requirements and with JHHS policy. Management’s Views and Corrective Action Plan Refer to Management’s View’s and Corrective Action Plan at the end of the report.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.181 Special Education-Grants for Infants and Families $2.23M
93.817 Hospital Preparedness Program (hpp) Ebola Preparedness and Response Activities $1.04M
93.926 Healthy Start Initiative $1.03M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.01M
93.RD National Institute of Neurological Disorders & Stroke Direct Award $513,131
93.493 Consolidated Appropriations Act $321,225
93.958 Block Grants for Community Mental Health Services $287,801
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $250,000
93.865 Child Health and Human Development Extramural Research $193,807
93.994 Maternal and Child Health Services Block Grant to the States $121,735
93.839 Blood Diseases and Resources Research $114,275
93.310 Trans-Nih Research Support $104,069
93.395 Cancer Treatment Research $103,975
93.788 Opioid Str $71,989
93.969 Pphf Geriatric Education Centers $65,163
93.959 Block Grants for Prevention and Treatment of Substance Abuse $49,243
10.558 Child and Adult Care Food Program $45,056
93.889 National Bioterrorism Hospital Preparedness Program $32,629
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $30,000
93.110 Maternal and Child Health Federal Consolidated Programs $16,646
93.838 Lung Diseases Research $15,903
10.559 Summer Food Service Program for Children $7,371
93.226 Research on Healthcare Costs, Quality and Outcomes $4,444
93.855 Allergy and Infectious Diseases Research $4,000
93.837 Cardiovascular Diseases Research $225
93.461 Covid-19 Hrsa Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $-434,379