Finding 1165373 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-12-18

AI Summary

  • Core Issue: The Organization did not adhere to its own procurement policies, failing to obtain required price quotations from qualified sources.
  • Impacted Requirements: This oversight affects compliance with 2 CFR section 200.320 and the Organization's internal procurement documentation standards.
  • Recommended Follow-Up: Ensure adherence to procurement policies and maintain proper documentation to support procurement decisions moving forward.

Finding Text

Procurement Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Federal Award Number: NU50CK000556 Award Periods: January 1, 2024 – July 31, 2024 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 by the non- Federal entity. Furthermore, the Organization's procurement policies require the maintaining of records sufficient to detail the history of procurement including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The Organization did not follow the procedures outlined within its internal policies related to the use of the simplified acquisition method of procurement, including maintaining the necessary documentation to show that price or rate quotations were obtained from an adequate number of qualified sources. Questioned Costs: $252,323. Context: This condition impacted four of five transactions selected for testing. Questioned costs are in accordance with the purpose of the grant, however occurred as a result of a lack of documentation. Cause: The timing of when grant was received (June 2024) and when the period of performance expired (July 2024), was just that the Organization had a limited amount of time to accomplish the program objectives. Thus, the organization used recurring vendors and did not follow the procurement policies and procedures outlined within their internal policies. Effect: The Organization could potentially use federal funds in a manner which is not the most efficient or economical. Repeat Finding: No. Recommendation: We recommend the Organization follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Procurement Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The Organization did not follow the procedures outlined within its internal policies related to maintaining documentation associated with purchases made via the simplified acquisition method of procurement. Recommendation: We recommend the organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management acknowledges that even though grant objectives were met, procurement procedures must be followed regardless of timeline constraints. Management has implemented enhanced controls to ensure compliance with internal procurement policies, including: (1) mandatory documentation for simplified acquisitions requiring evidence of price reasonableness; (2) staff meetings on procurement requirements; and (3) supervisory review of procurement files prior to grant invoice submission. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Nelson Planned completion date for corrective action plan: 7/1/2025

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1165374 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.788 OPIOID STR $649,999
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $572,510
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $316,037
93.926 HEALTHY START INITIATIVE $207,908
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $192,699
93.667 SOCIAL SERVICES BLOCK GRANT $89,708
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $79,836
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $79,343
93.332 COOPERATIVE AGREEMENT TO SUPPORT NAVIGATORS IN FEDERALLY-FACILITATED EXCHANGES $59,511
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $34,834