Finding Text
Federal Agency: Department of Health and Human Services
Federal Program: Research and Development Cluster
Assistance Listing Number: 93.847, 93.867, & 93.103
Federal Award Identification Number and Year: Various
Award Period: January 1, 2024, through December 31, 2024
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires organizations to have a written procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars.
Condition: Prior to October 2024 the Organization did not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations.
Questioned Costs: None
Context: The new policy was implemented in October 2024. Our testing concluded that the new policy covers the requirements noted in Section 200.318 of the Code of Federal Regulations. In addition, 8 of the transactions in our sample for procurement testing fall under the new policy, and we noted no instances of noncompliance in those 8 transactions. This finding is recurring solely because the new policy was not in place prior to October 2024.
Cause: The new policy was being developed during 2024
Effect: Noncompliance with federal procurement requirements
Repeat Finding: Yes, 2023-001
Recommendation: We recommend that the Organization follow the new policy going forward.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.