Finding 1147118 (2024-002)

PROCUREMENT, SUSPENSION & DEBARMENT Federal Agency: Department of Health and Human Services Federal Program or Cluster: Grants for Capital Development in Health Centers Assistance Listing Number: 93.526 Federal Award Numbers and Years Award Period: 9/15/21-8/31/25 - 4 C8ECS44755-01-07 Questioned Costs $0 Condition: The Organization did not follow its internal procurement policy or the guidelines for procurement in the Uniform Guidance. The Organization did not solicit the correct number of bids to align with its internal policy, nor did it document the adequacy of the number it did procure to align with federal guidelines for a small threshold project. The Organization selected a vendor it had worked with previously and did not document criteria for selecting this vendor rather than requesting multiple bids. Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls, policies and procedures in place designed to ensure compliance with these provisions. Cause: The Organization has not updated its internal processes and procedures related to procurement, suspension and debarment for several years. The dollar amounts included in the policy are out of date. However if this policy would have been followed, the Organization would have been in compliance with current laws and regulations regarding purchases and procurement requirements as the thresholds were less than those allowed under the Uniform Guidance. Effect: The Organization could pay more than necessary for comparative services and goods. Recommendation: We recommend the Organization review, update, and follow its procurement policy to ensure compliance with the Uniform Guidance. Identification of repeat findings: This is not a repeat finding. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Management will review its existing procurement policy and update as necessary. Staff involved in projects and procurements will receive training regarding the policy and federal guidelines for federally funded projects. Management will ensure staff adhere to the policy prospectively.