Finding Text
Assistance Listing Number: 93.193 Name of Federal Program: COVID-19 Urban Indian Health Services Name of Federal Agency: Department of Health and Human Services Award Period: January 1, 2024 – December 31, 2024 Criteria or Specific Requirement: 2 CFR section 200.318(i) requires a non-federal entity to maintain sufficient records to detail the history of procurement including, but not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The organization did not maintain adequate records to fully detail the history of procurement transactions funded with federal awards. Specifically, documentation was missing or incomplete regarding the rationale for the method of procurement, basis for contractor selection or rejection, price or cost analysis, and contract terms. Cause: The organization did not establish or enforce adequate recordkeeping procedures for procurement transactions. Supporting documentation for procurement files was not retained. Procurement policies and procedures have not been designed and implemented that adhere to Uniform Guidance requirements. Effect or Potential Effect: Without sufficient records, the organization cannot demonstrate compliance with Uniform Guidance procurement requirements. This increases the risk of unallowable or unreasonable costs being charged to federal awards and may result in questioned costs or funding agency disallowances. Questioned Costs: $194,797 Context: All vendors meeting the procurement policy threshold were tested. Repeat Finding: No Recommendation: Management should implement procedures to ensure that complete procurement documentation is maintained in accordance with 2 CFR §200.318(i). This should include standardized procurement checklists, training for staff involved in purchasing, and periodic internal reviews to confirm that procurement files contain all required documentation. Views of Responsible Officials: Management agrees with the finding and will implement procurement procedures.