Finding 1175414 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-02-25
Audit: 389155
Organization: Chestnut Health Systems, INC (IL)

AI Summary

  • Core Issue: The Organization did not keep enough documentation to support the procurement method used for a vendor, leading to questioned costs of $252,500.
  • Impacted Requirements: This finding raises concerns about compliance with 2 CFR section 200.320(b), which mandates formal procurement methods for purchases over the simplified acquisition threshold.
  • Recommended Follow-Up: The Organization should ensure it consistently follows its own policies for maintaining documentation related to procurement methods.

Finding Text

Finding 2025-001 – Procurement Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Drug use and addiction research programs Assistance Listing Number: 93.279 Pass-Through Entity: N/A Pass-Through Number: N/A Award Periods: May 1, 2023 – April 30, 2025 Criteria: 2 CFR section 200.320(b) outlines the acceptable formal procurement methods. Formal procurement methods are required when the value of the procurement exceeds the simplified acquisition threshold. Acceptable methods include sealed bids or proposals. Condition: The Organization did not maintain sufficient documentation to support the procurement method utilized. Questioned Costs: $252,500. Context: One of three procurement transactions selected for testing. Cause: The Organization failed to maintain necessary documentation to demonstrate compliance with the procurement method utilized for a vendor selected for testing. Effect: Potential for noncompliance with 2 CFR section 200.320(b)(1) - (2). Repeat Finding: No. 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. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

United States Department of Health and Human Services 2025-001 Procurement – Assistance Listing No. 93.279 Condition: The Organization did not maintain sufficient documentation to support the procurement method utilized prior to engaging a contracted service provider. 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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Given the infrequency of spend in excess of the Simplified Acquisition Threshold, Chestnut will take a targeted approach in the corrective action. An initial first step in correction action has been taken and completed 2/18 including educating and informing Chestnut Health Systems Audit Committee and Chestnut Executive Leadership of lack of documentation supporting the procurement process. The Executive Leadership team and assigned grant leadership will be provided with the current Chestnut Procurement policy, reinforcing the requirements at each respective level of spend. For those programs with anticipated vendor spend in excess of the Simplified Acquisition Threshold, targeted working sessions will occur with respective program leadership and the Executive Leadership team to reinforce expectations, review template tools that can be leveraged during the process, and to remedy any gaps in understanding the policy and execution of the policy. Name(s) of the contact person(s) responsible for corrective action: Melissa Woodbury, CFO. Planned completion date for corrective action plan: By June 1, 2026 If there are any questions regarding this plan, please call Melissa Woodbury, CFO, at 309-820-3572.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
64.033 VA SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM $1.37M
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.13M
93.658 FOSTER CARE TITLE IV-E $743,360
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $517,978
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $504,845
93.912 RURAL HEALTH CARE SERVICES OUTREACH, RURAL HEALTH NETWORK DEVELOPMENT AND SMALL HEALTH CARE PROVIDER QUALITY IMPROVEMENT $419,377
93.273 ALCOHOL RESEARCH PROGRAMS $378,734
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $372,121
14.267 CONTINUUM OF CARE PROGRAM $223,639
93.495 COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $205,206
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $195,993
93.667 SOCIAL SERVICES BLOCK GRANT $170,200
93.276 DRUG-FREE COMMUNITIES SUPPORT PROGRAM GRANTS $122,769
93.788 OPIOID STR $117,025
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $107,324
93.242 MENTAL HEALTH RESEARCH GRANTS $41,172
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $18,000
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $10,046