Finding 1153102 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2024
Accepted
2025-09-15
Audit: 366335
Auditor: Baker Tilly

AI Summary

  • Core Issue: A contract exceeding the simplified acquisition threshold was awarded without following required formal procurement methods.
  • Impacted Requirements: The Organization did not comply with federal regulations outlined in 2 CFR 200.320, specifically regarding procurement methods.
  • Recommended Follow-Up: Implement controls to ensure all contracts over the threshold adhere to procurement requirements and maintain proper documentation for compliance.

Finding Text

Criteria or specific requirement: Federal regulations require that for acquisitions exceeding the simplified acquisition threshold, the nonfederal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR 200.320(c); the competitive proposals method under the conditions specified in 2 CFR 200.320(d); or the noncompetitive proposals method (i.e., solicit a proposal from only one source), but only when one or more of four circumstances are met in accordance with 2 CFR 200.320(f). Condition: For one of the four contracts tested, the Organization followed its internal policy allowing for preferred vendor selection, which states frequently used vendors can be vetted in advance of use and can eliminate the need for bids; however, the contract exceeds the simplified acquisition threshold and must follow formal procurement methods. Formal procurement methods are competitive and require public notice. The Organization did not meet the criteria in 2 CFR 200.320(f) for noncompetitive procurement. Context: Of the four vendors that had expenditures greater than $25,000, we selected four vendors for procurement testing. One of the four vendors had a contract that exceeded the simplified acquisition threshold. The total value of the contract award is $663,190, the amount committed in future years is $442,127 and the questioned costs during the year ended June 30, 2024 totaled $221,063. Effect: The Organization awarded a contract to a vendor that exceeded the simplified acquisition threshold. This project did not follow the required formal procurement process. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Repeat finding: No Recommendation: The Organization should ensure that all contracts exceeding the simplified acquisition threshold follow procurement methods outlined in 2 CFR 200.320. Additionally, the Organization should implement controls to verify and maintain documentation of contract approvals to ensure compliance with federal regulations under 2 CFR 200.320. Views of responsible officials: Management agrees with the auditor recommendation

Corrective Action Plan

Corrective action planned – Management recognizes that procurement is a material concern of the organization both from an operational efficiency and regulatory compliance perspective. During the audited time period, procurement responsibilities were decentralized, resulting in inconsistent compliance. In April 2025, Management decided to create a dedicated Procurement Department and began staffing the department. The new Procurement team is tasked with reviewing all current procurement policies and procedures, revising and creating new processes as needed, and partnering with the compliance team to monitor compliance going forward. The policy and procedure revisions will be implemented by the end of the fourth quarter of 2025. Staff will receive training by the first quarter of 2026, and after the training rollout, we will begin internal audits to ensure successful training, implementation and compliance with the new policies and procedures. Name(s) of contact person(s) responsible for corrective action – Alison Spens, Senior Director of Project Management and Procurement Anticipated completion date – August 15, 2025

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1153095 2024-001
    Material Weakness Repeat
  • 1153096 2024-002
    Material Weakness Repeat
  • 1153097 2024-001
    Material Weakness Repeat
  • 1153098 2024-002
    Material Weakness Repeat
  • 1153099 2024-001
    Material Weakness Repeat
  • 1153100 2024-002
    Material Weakness Repeat
  • 1153101 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.696 Certified Community Behavioral Health Clinic Expansion Grants $819,982
14.267 Continuum of Care Program $443,747
21.027 Coronavirus State and Local Fiscal Recovery Funds $300,619
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $267,900
84.126 Rehabilitation Services Vocational Rehabilitation Grants to States $125,393
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $103,720
14.239 Home Investment Partnerships Program $99,852
14.195 Project-Based Rental Assistance (pbra) $98,313
14.241 Housing Opportunities for Persons with Aids $68,407
93.150 Projects for Assistance in Transition From Homelessness (path) $26,254
14.231 Emergency Solutions Grant Program $16,330
93.959 Block Grants for Prevention and Treatment of Substance Abuse $11,827
93.958 Block Grants for Community Mental Health Services $10,000