Finding Text
ALN Number and Title: 93.576 Refugee and Entrant Assistance Discretionary Grants Federal Agency: U.S. Department of Health and Human Services Federal Award Number: 9OZZ0013-01-01 (Direct award) Grant period: October 1, 2023 - September 30, 2024 Criteria: Procurement - Non-profit entities must follow the procurement standards set out at 2 CFR part 200. Condition: Lack of documentation of the history of procurement including the rationale for the method of procurement and the Organization's procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. In addition, the conflict of interest policy was inadvertently removed from the procurement policy when the financial policies manual was updated in June 2024. Cause: Staff did not follow policies. Effect: The Organization does not have adequate documentation to support rational for procurement method. In addition, procurement policy related to conflicts of interest is not documented. Context: A sample of 2 disbursements totaling $26,400 tested from a population of 8 transactions over the micro purchase threshold totaling $109,557 for the period October 1, 2023 through September 30, 2024. Questioned costs: No known or likely questioned costs over $25,000. Repeat finding: No. Recommendation: We recommend the Organization adhere to its policy for documenting procurement and update its financial policies manual to include required conflict of interest policy in accordance with 2 CFR part 200. Views of responsible officials of the auditee: Management is reviewing all finance policies and procedures as the Organization moves forward with creating a revised Finance Policies Manual. Management has taken the step of moving the Conflict-of-Interest policy to the current Finance Policies Manual. Management will train all staff on the proper policies for documenting procurement.