Finding Text
Mental and Behavioral Health Education and Training Grants Assistance Listing No. 93.732 U.S. Department of Health and Human Services Program Year 2024 Criteria or Specific Requirement – Procurement, Suspension and Debarment (2 CFR 200.317 – 200.327; 2 CFR 180.220) Condition – The District is required to follow its own documented procurement procedures which conform to the Uniform Guidance procurement standards. Questioned Costs – $56,306 - calculated as contracts tested that were not properly procured and known contracts tested in prior years that were not properly procured. Context – Out of a population of five contracts directly charged to the grant that were above the micro-purchase threshold, two contracts were selected for testing. Our sampling method was not and was not meant to be statistically valid. The District did not obtain price or rate quotations from an adequate number of qualified sources for one of the vendors selected for testing. Although not selected for testing, the vendor related to the 2023-001 finding was also included in the population of contracts directly charged to the grant. Therefore, questioned costs also include expenses for a second vendor for which it is known the District did not obtain price or rate quotations from an adequate number of qualified sources. Effect – The District did not provide for full and open competition in procuring services with grant funds. Cause – The District included the vendors in the grant application and program narrative which was approved by the grantor. After notification of approval, the District moved forward with the vendors and did not follow procurement guidelines. Identification as a repeat finding – 2023-001 Recommendation – Contracts directly charged to a federal award should be reviewed to ensure compliance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions – Responsible Official: Aaron Davis, VP & Chief Experience Officer Planned Corrective Actions: The first contract in question was for a vendor (Healthsource Solutions) already under contract with the District prior to the grant application. The vendor in question had been used since at least 2010, with the most recent contract for the current wellness portal (Wellness +) beginning in 2017. Because of the success of the wellness portal and established relationship with the vendor, the District included expansion of existing platforms and additional services provided by Healthsource Solutions as a large component of the Methodology/ Approach in the proposed activities of the grant narrative submitted. Use of this vendor and its applications were specifically outlined in the grant project narrative and a critical component of meeting grant objectives. The second contract in question was for the Evaluation Group, which provided specific services around grant program evaluation. This vendor was included in the original grant application and selected via the grant consultant used during the grant application process. The District follows the Lubbock County Purchasing Guidelines, which conform to the Uniform Guidance procurement standards. The District has reviewed the specified requirements of the Uniform Guidance for procurement standards, specifically related to noncompetitive procurement and concurs that formal procurement methods were not used for expansion of new services with this existing vendor nor was adequate documentation provided for noncompetitive procurement. In order to ensure compliance with the Uniform Guidance, the District will provide training to existing grant Program Managers on Uniform Guidance procurement standards. Additionally, if a new grant is being pursued, the grant committee should receive training on Uniform Guidance procurement standards before completing grant applications. On existing or future grants, any potential contracts or purchases over $75,000 should be reviewed by the grant Program Manager (or Grant Committee lead if a Program Manager has not yet been assigned) to ensure all procurement guidelines are followed and sufficient documentation is obtained prior to purchase or contract execution.