Finding 1141812 (2024-001)

Program Information: Cluster: Research and Development Cluster Federal Program: Child Health and Human Development Extramural Research ALN: 93.865 Federal Agency: United States Department of Health and Human Services Pass-through entity: N/A Grant Name(s): Influence of Maternal Virome and HIV Status on Infant Gut Virome, Growth, and Immunity; Influence of HIV Infection on Vaginal Virome and Risk of Preterm Birth in Pregnant South African Women Grant ID Number Federal Award Year 5R01HD102239-04 9/21/2020 – 8/30/2025 5R01HD106821-04 9/9/2021 – 7/31/2026 Criteria or requirement: Per 2 CFR 200.320(a)(2)(i): Simplified acquisition procedures. The aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If simplified acquisition procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Unless specified by the Federal agency, the recipient or subrecipient may exercise judgment in determining what number is adequate. Condition found, including facts that support the deficiency identified in the finding and information to provide proper perspective for judging the prevalence and consequences of the finding: For 2 out of 40 procurement selections tested, totaling $22,675, the entity did not obtain price or rate quotations as required by its procurement policies. Both selections, related to the same purchase invoice, were above the micro-purchase threshold and were related to cost transfers to federal awards. Cause and possible asserted effect: The entity did not have a control in place to review cost transfers to federal awards to ensure the entity followed the appropriate procurement policies for these costs. Without adequate controls over cost transfers, there is an increased risk of non-compliance with procurement policies. Identification of questioned costs and how they were computed: Known questioned costs identified as part of this finding were $22,675. Sample Statistically Valid: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding from prior year: No Recommendation: We recommend that management design and implement a control to review cost transfers to federal awards to ensure that the entity follows its procurement policies. Views of Responsible Officials: Management will design and implement a control to review cost transfers from non-federal awards to federal awards to ensure we follow our procurement policies. This will be achieved by adding a new step to the non-payroll cost transfer form that requires the requestor to include a copy of the Procurement authorization form if the procurement policies apply. The Procurement authorization form documents the process, rationale, and justification for procurements. If the purchase being transferred did not go through the appropriate procurement procedures at the time of purchase, then the transfer from the non-federal award to the federal award will not be allowed. Management will also provide additional training around procurement and our related policies and ensure staff involved in this area are aware of the new step embedded in the non-payroll cost transfer form.