Finding Text
Finding 2024-004 – PROCUREMENT (repeat finding)
Type: Material Weakness in Internal Control/Noncompliance.
Program: ALN 93.493 Congressional Directives
Grant Name: Access to Behavioral Crisis Services
Grantor Number: FG-22-099
Criteria: Pursuant to 2 CFR 200.320, when a procurement transaction under a Federal award exceeds the simplified acquisition threshold, formal procurement methods are required.
Pursuant to 2 CFR 200.214 and 2 CFR part 180, prior to entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified.”
Condition: The CMHSP did not follow the formal procurement methods outlined in 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant.
Cause: This condition was caused by an insufficient internal control process for procurement including 1) requirement/review and approval of formal bid, and 2) review for suspension and debarment.
Effect: The CMHSP purchased several items pursuant to a contract that did not go through a formal bid process or have evidence of review for suspension and debarment.
Questioned Cost: $340,014
Context: One contract was paid from grant funds. The questioned cost shown above reflects the amount paid from grant funds for the year pursuant to this contract which did not go through a formal bid process or have evidence of review for suspension and debarment. Upon subsequent review, it was determined that the vendor was not suspended, debarred, or otherwise excluded or disqualified.
Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that procurements adhere to the requirements of 2 CFR 200.
Management’s Resp: We are in agreement with this finding.