Finding 1157064 (2024-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369390
Organization: Unity Health Care, Inc. (MD)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The Corporation failed to provide evidence of adherence to procurement standards outlined in 2 CFR Sections 200.317-200.327, specifically lacking documentation for competitive price analysis and sole source procurements.
  • Impacted Requirements: Non-compliance with federal procurement standards raises concerns about whether vendor charges align with required regulations.
  • Recommended Follow-Up: Establish formal internal controls and documentation practices for procurement processes, including vendor price analysis and compliance verifications.

Finding Text

Criteria: The Corporation must maintain and adhere to documented procurement procedures that must conform to the procurement standards in 2 CFR Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement. Condition: We noted that there was a lack of evidence that policies and procedures were applied as required under the noted 2 CFR Sections in “Criteria”. During our testing of procurement, the Corporation was unable to provide evidence to support that a competitive price analysis for 1 vendor out of the 3 samples. Additionally, per management, no written documentation can be provided for any sole source procurements. Cause: The Corporation did not maintain formal documentation or evidence to support that a competitive price analysis for vendors, as required by the general procurement standards of the Uniform Guidance. Effect or Potential Effect: We were unable to determine whether charges relating to vendor services or goods charged to the Federal programs are in accordance with 2 CFR Sections 200.317 through 200.327 or 200.214. Questioned costs: None Context: We tested a sample of 3 procurements and found exceptions as noted in the condition. This is a condition identified per review of the Corporation’s compliance with specified requirements using a statistically valid sample. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2023-007 in the 2023 report. Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating procurement, required price analysis of vendors, and suspension and debarment verifications. View of Responsible Officials: Previously, the company faced challenges in effectively monitoring and documenting grant activity due to limited formal processes. Documentation of policies and procedures was insufficient, and supporting materials were not stored in a centralized location, making information retrieval difficult. Since then, processes have improved, with enhanced documentation practices and better organization of grant-related records to support more efficient oversight and compliance.

Corrective Action Plan

Management Response #2024-003: Previously, the Corporation faced challenges in effectively monitoring and documenting grant activity due to limited formal processes. Documentation of policies and procedures was insufficient, and supporting materials were not stored in a centralized location, making information retrieval difficult. Since then, processes have improved, with enhanced documentation practices and better organization of grant-related records to support more efficient oversight and compliance. Corrective Action Plan: The Corporation has implemented the following corrective measures: • The Corporation established comprehensive, formal policies and procedures that document the current compliance practices. These procedures have been disseminated across the organization and incorporated into training programs to ensure all employees are aligned with the updated standards. • A procedure enhancement has been implemented in the procurement process, which requires the procurement manager to obtain three bids prior to the creation of certain purchase orders. This ensures competitive bidding and transparency in vendor selection. • Once a vendor is selected, the procurement manager will forward the vendor’s details to the compliance department. The compliance team will then verify the vendor's debarment status and federal eligibility to ensure compliance with all regulatory requirements. • A central repository platform has been created to store all vendor bids, price analyses, and related procurement documentation. This ensures that all relevant information is easily accessible and properly organized. • All accounts payable invoices designated for grant funding are now routed for prior approval to the respective grant program manager via the WorkPlace software before any payments are processed. This ensures proper oversight and alignment with grant requirements. These corrective actions aim to strengthen compliance, improve document management, and streamline oversight processes to prevent future issues related to grant monitoring and procurement. Management expects to be completed by December 31, 2026. Responsible Party: Tamara Barnes, CFO

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1157059 2024-001
    Material Weakness Repeat
  • 1157060 2024-002
    Material Weakness Repeat
  • 1157061 2024-003
    Material Weakness Repeat
  • 1157062 2024-001
    Material Weakness Repeat
  • 1157063 2024-002
    Material Weakness Repeat
  • 1157065 2024-001
    Material Weakness Repeat
  • 1157066 2024-002
    Material Weakness Repeat
  • 1157067 2024-005
    Material Weakness Repeat
  • 1157068 2024-001
    Material Weakness Repeat
  • 1157069 2024-002
    Material Weakness Repeat
  • 1157070 2024-005
    Material Weakness Repeat
  • 1157071 2024-001
    Material Weakness Repeat
  • 1157072 2024-002
    Material Weakness Repeat
  • 1157073 2024-005
    Material Weakness Repeat
  • 1157074 2024-001
    Material Weakness Repeat
  • 1157075 2024-002
    Material Weakness Repeat
  • 1157076 2024-004
    Material Weakness Repeat
  • 1157077 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $7.41M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $5.37M
93.788 Opioid Str $1.47M
93.914 Hiv Emergency Relief Project Grants $1.24M
93.217 Family Planning Services $1.11M
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $451,849
93.917 Hiv Care Formula Grants $395,938
93.247 Advanced Nursing Education Workforce Grant Program $343,619
93.855 Allergy and Infectious Diseases Research $330,035
93.994 Maternal and Child Health Services Block Grant to the States $287,682
93.837 Cardiovascular Diseases Research $259,513
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $118,679
93.884 Primary Care Training and Enhancement $99,465
93.527 Grants for New and Expanded Services Under the Health Center Program $72,274
93.526 Grants for Capital Development in Health Centers $62,276
93.426 The National Cardiovascular Health Program $57,990
93.107 Area Health Education Centers $53,711
93.242 Mental Health Research Grants $1,519