Finding 1147095 (2022-004)

Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Procurement, Suspension and Debarment – 45 CFR 75.329, 2 CFR 180 Condition – For procurement testing, a sample of 3 procurements was selected from a population of 12 totaling $537,276. For suspension and department testing, a sample of 2 was selected from a population of 7 totaling $469,071. The samples were not, and are not intended to be, statistically valid. Of the samples tested, the following were determined to lack appropriate supporting documentation for compliance requirement: • Procurement: 3 items totaling $216,847, including projected errors over the total population totaling $537,276 • Suspension and debarment: 2 items totaling $157,617, including projected errors over the total population totaling $469,071 Procurement procedures were not followed for vendors with greater than $10,000 in purchases of goods or services charged to the federal award. In addition, the Organization does not have adequate policies governing suspension and debarment requirements for the purchase of goods or services charged to federal awards. Specifically, the Organization did not verify that vendors were not suspended, debarred, or otherwise excluded. Cause – The Organization did not comply with their procurement policy. In addition, the Organization does not include a review of the federal suspended and debarment party list as part of the Organization's procurement policy. Effect or potential effect – Procurement methodology was not followed for vendor with expenses of over $10,000. In addition, that did not adhere to the federal government's suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization did not have adequate policies and procedures to ensure procurement, suspension, and debarment requirements were met prior to the purchase of goods or services charged to federal awards. Upon further discussion with Tuerk House, Inc., no procurement, suspension and debarment procedures were performed on any vendors. Identification as a repeat finding – Not a repeat finding Recommendation – We recommend management continue to ensure all personnel understand the procurement policy and adhere to the requirements and guidelines set forth in the policy. Procedures should be implemented to ensure that vendors, especially those over $10,000, are selected and vetted in accordance with policy and Uniform Guidance. In addition, policies and procedures should be put in place to ensure all vendors are not included on the suspended and debarred listing.