Finding Text
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS12856 Award Periods: March 1, 2023 – February 29, 2024 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate supporting documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the organization did not maintain appropriate documentation to support the procurement method utilized for contracts selected for testing. Questioned costs: None. Context: Eight (8) of eight (8) procurement transactions selected for testing. Cause: The Organization did not create and maintain appropriate documentation to support the method of procurement utilized. Effect: Possible noncompliance with 2 CFR section 200.320(c)(1) - (3). Repeat finding: No. Recommendation: We recommend the Organization revise its procurement and suspension and debarment policies to be consistent with the Uniform Guidance and consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Views of responsible officials: There is no disagreement with the audit finding.