Finding Text
PROCUREMENT AND SUSPENSION AND DEBARMENT - SMALL, FORMAL, AND NONCOMPETITIVE PROCUREMENTS Finding Type: Significant Deficiency in Internal Controls over Compliance, Noncompliance ALN/CSFA and Program Title: 93.676 – Unaccompanied Alien Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Liberty Wilderness Crossroads Camp Contract Number: 90ZU0362 (direct), 90ZU0501 Criteria: 2 CFR 200 Subpart D of the Uniform Guidance outlines standards for procurement transactions made with federal funds. Additionally, 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The auditor tested 4 small, formal, and noncompetitive procurements and noted the following: 1. For 3 procurements that were also covered transactions, all necessary documentation of the procurement process was not maintained, the procurement method used was incorrect or there was no documented justification for the procurement to be noncompetitive, and there was no evidence the Organization verified that vendor was not suspended or debarred. 2. For 2 procurements, the contracts did not contain all necessary federal provisions. This was not a statistically valid sample. Cause: The Organization’s policies and procedures for purchasing are not adequate. Effect: Procurements were potentially not made in compliance with Uniform Guidance. Questioned Costs: None Recommendation: We recommend the Organization update its policies and procedures for purchasing and suspension and debarment to align with Uniform Guidance or other requirements, whichever are more restrictive, and maintain all necessary documentation of the procurement process for purchases. Views of Responsible Officials and Planned Corrective Actions: See management’s response and Corrective Action Plan on page 57.