Finding Text
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 2 procurements was
selected from a population of 7 totaling $368,608. For suspension and
department testing, a sample of 1 was selected from a population of 3 totaling
$310,009. 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: 2 items totaling $209,209, including projected errors
over the total population totaling $368,608
• Suspension and debarment: 1 item totaling $162,900, including
projected errors over the total population totaling $310,009
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 – Repeat finding (see 2022-004)
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.