Finding 1127556 (2024-003)

Federal Agency: United States Department of Health and Human Services Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers 93.129, 93.527 Federal Award Year: 2023-2024 Criteria or specific requirement – Procurement (2 CFR 200.318) and suspension and debarment (2 CFR 180) The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Organization was unable to provide evidence it was in compliance with its procurement policy or that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Organization did not have adequate controls and procedures in place relating to procurement and suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – We were unable to determine whether the Organization complied with these compliance requirements. Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded. Questioned Costs – None Context – The Organization was unable to provide a detailed expenditure listing by vendor to verify compliance with its procurement policy and compliance with Uniform Guidance. The Organization was also unable to provide evidence covered transactions were not with vendors suspended, debarred or otherwise excluded. Identification as a Repeat Finding– Yes Recommendation – The Organization should incorporate internal controls over compliance with the procurement and suspension and debarment compliance requirements, including reviewing its procurement policy for compliance with Uniform Guidance and monitoring vendors against the exclusions list. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the audit finding related to procurement and suspension and debarment compliance under Federal Programs: Technical and Non-Financial Assistance to Health Centers, Grants for New and Expanded Services under the Health Center Program (Federal Assistance Listing Numbers 93.129, 93.527; Federal Award Year 2023-2024). We are committed to implementing corrective measures to address the identified deficiencies and ensure full compliance with 2 CFR 200.318 and 2 CFR 180 regulations. Corrective Actions Taken: 1. Established & Implemented Detailed Record-Keeping for Procurement Transactions: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor invoices and procurement transactions in real time and syncs with Sage Intacct, the new accounting software implemented in January 2024. - Detailed records of all federal grant expenditures are maintained in Bill.com and monthly reconciliations are conducted in the general ledger to ensure all procurement transactions are properly classified to their specific grant by their grant ID. 2. Established & Implemented Suspension & Debarment Verification Procedures: - A new accounting system with a centralized procurement tracking system has been implemented and is currently being used. Bill.com is used to record vendor information including Sam.gov vendor eligibility documentation. - All vendors are verified using Sam.gov. and documentation is kept in the electronic vendor file in Bill.com. This process was implemented in March 2024 and is ongoing. 3. Monitoring - The Finance team conducts annual self-assessments to ensure vendor eligibility documentation is current and up to date. Any vendors that are suspended, debarred, or otherwise excluded from federal assistance programs are reported to the Executive team to ensure compliance. We believe that these actions will significantly mitigate the risks associated with the identified conditions and strengthen our internal control environment and align our procurement practices with federal regulations.