Finding 1135696 (2024-002)

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EveryStep should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted EveryStep did not have adequate internal controls designed to ensure vendors were in compliance with federal regulations. Questioned costs: None Context: During our testing, it was noted that EveryStep did not have a formal procurement policy to ensure vendors are in compliance with federal regulations, including obtaining competitive bids, documenting justifications for sole-source purchases, and properly managing conflicts of interest. Cause: EveryStep was no formal policy documented. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No. Recommendation: We recommend EveryStep design controls to ensure a formal policy is in place. Views of responsible officials: There is no disagreement with the audit finding.