Finding 1162479 (2024-007)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-11-17

AI Summary

  • Core Issue: HAH did not follow procurement policies as required by federal regulations, specifically failing to obtain multiple bids for purchases exceeding the micro-purchase threshold.
  • Impacted Requirements: Compliance with Uniform Guidance 2 CFR 200.318 was not met, leading to inadequate internal controls over procurement processes.
  • Recommended Follow-Up: HAH should update its procurement policy and assign a responsible individual to review and ensure compliance for all significant purchases.

Finding Text

Federal Procurement Regulations Significant Deficiency U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES ALN #: 93.224 - Health Centers Program and 93.527 - Grants for New and Expanded Services under the Health Center Program Federal Award Identification #: 20H80CS00111, 24H80CS00111, 21H8FCS40976, 23H8GCS47647 Condition: During the Health Centers Program audit, it was noted that HAH did not follow their procurement policies as required by the Uniform Guidance 2 CFR 200.318. Criteria: 2 CFR 200.318 Questioned Costs: $0 Context: During the audit, it was noted that while the majority of program expenditures are salary and benefits, HAH did not follow their policies for procurement for other goods and services, and did not obtain multiple bids or sole source justification for any purchases that exceeded the micro-purchases threshold. Cause: Turnover at HAH, who separated from the parent entity in FY24 resulting in changes in procedures. Effect: Lack of internal control to ensure program requirements Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that HAH establish an updated procurement policy and designate an individual to review all purchases over the micro-purchases threshold and review procurement documentation to ensure it is sufficient before expenses are approved for payment. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Federal Procurement Regulations Planned Corrective Action: Heartland Alliance Health developed and implemented a comprehensive Procurement Policy to ensure full compliance with federal Uniform Guidance requirements. The policy outlines required procurement methods, approval thresholds, documentation standards, and procedures for competitive bidding, price analysis, and sole-source justifications. The policy was reviewed and approved by the Board of Directors (October 2025) and is now in effect organization wide. Person Responsible for Corrective Action Plan: Steve Knox, Controller Anticipated Date of Completion: Resolved

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1162455 2024-003
    Material Weakness Repeat
  • 1162456 2024-003
    Material Weakness Repeat
  • 1162457 2024-003
    Material Weakness Repeat
  • 1162458 2024-003
    Material Weakness Repeat
  • 1162459 2024-003
    Material Weakness Repeat
  • 1162460 2024-003
    Material Weakness Repeat
  • 1162461 2024-003
    Material Weakness Repeat
  • 1162462 2024-003
    Material Weakness Repeat
  • 1162463 2024-003
    Material Weakness Repeat
  • 1162464 2024-003
    Material Weakness Repeat
  • 1162465 2024-003
    Material Weakness Repeat
  • 1162466 2024-003
    Material Weakness Repeat
  • 1162467 2024-003
    Material Weakness Repeat
  • 1162468 2024-003
    Material Weakness Repeat
  • 1162469 2024-004
    Material Weakness Repeat
  • 1162470 2024-005
    Material Weakness Repeat
  • 1162471 2024-005
    Material Weakness Repeat
  • 1162472 2024-006
    Material Weakness Repeat
  • 1162473 2024-006
    Material Weakness Repeat
  • 1162474 2024-006
    Material Weakness Repeat
  • 1162475 2024-006
    Material Weakness Repeat
  • 1162476 2024-007
    Material Weakness Repeat
  • 1162477 2024-007
    Material Weakness Repeat
  • 1162478 2024-007
    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) $2.77M
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $683,616
93.323 COVID-19 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $388,539
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $330,388
93.917 HIV CARE FORMULA GRANTS $259,851
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $129,478
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $123,050
93.527 COVID-19 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $122,431
93.924 RYAN WHITE HIV/AIDS DENTAL REIMBURSEMENT AND COMMUNITY BASED DENTAL PARTNERSHIP GRANTS $92,067
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $60,545
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $59,855
93.011 COVID-19 NATIONAL ORGANIZATIONS FOR STATE AND LOCAL OFFICIALS $32,939
93.247 ADVANCED NURSING EDUCATION WORKFORCE GRANT PROGRAM $27,280
14.267 CONTINUUM OF CARE PROGRAM $25,361