Finding Text
Finding 2024-002 – Procurement and Suspension and Debarment — Material Weakness
Department of Health and Human Services
Research and Development Cluster
Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training)
Federal award year 2023-2024
Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement methods outline by the University are properly followed.
In accordance with 2 CFR 200.320, price quotations should be obtained from an adequate number of qualified sources for procurements that meet the small purchase procurement threshold.
Condition: The University’s controls were not operating effectively to reasonably ensure the University obtained the proper number of price quotations as required using the small purchase procurement method. The University’s procurement policy requires price quotations be obtained from at least two sources when using the small purchase procurement method. The University only obtained one price quotation and no written documentation as the rational for selection was maintained. As a result, the University did not comply with the compliance requirements for procurement.
Cause: The University does not have processes and procedures in place to ensure all procurements of goods and services are in accordance with Uniform Guidance and in accordance with it’s own procurement policy.
Effect or potential effect: The University is not in compliance with federal grant requirements over small purchase procurements. Improper procurement procedures could result in actions taken by oversight agencies which could impact future funding.
Questioned costs: None
Context: For all sample selections tested in the major program, one price quotation was obtained and no documentation was maintained as to the rationale for selection of the underlying vendor.
Identification as a repeat finding, if applicable: Not applicable.
Recommendation: We recommend the University develop processes and procedures to obtain the required number of price quotations required under the small purchase procurement method, and maintain support for the required number of price quotations received under the small purchase procurement method.
View of responsible officials: Management agrees with this finding. See corrective action plan.