Finding 1179026 (2023-010)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-03-12

AI Summary

  • Core Issue: Lack of tested procurement transactions due to discrepancies in records, leading to an inability to verify compliance with federal requirements.
  • Impacted Requirements: Non-compliance with documented procurement procedures, competition, and contractor verification as per Uniform Guidance.
  • Recommended Follow-Up: Strengthen internal controls by tracking procurement transactions, maintaining complete records, reconciling expenditures, and establishing formal record-retention procedures.

Finding Text

Federal Agency: U. S. Department of Health and Human Services Cluster: Health Centers Clusters AL No.: 93.224 Program Title: Community Health Centers Area: Procurement and Suspension and Debarment Repeat Finding from Prior Audit? Yes Finding Type: Material Weakness in Internal Control over Compliance Questioned Cost: Unable to be determined Criteria: Under Uniform Guidance (2 CFR §§200.317–200.327), non-federal entities must follow documented procurement procedures that provide for full and open competition and maintain records sufficient to detail the history of procurement. In addition, non-federal entities must verify that contractors are not suspended or debarred prior to contract award. Condition: No procurement transactions were tested. The auditors were unable to identify a reliable population of procurement transactions attributable to this program due to discrepancies between the SEFA and underlying accounting and procurement records. Cause: The SEFS for AL No. 93.224 did not reconcile to underlying accounting records, and procurement documentation specific to the program was not sufficiently available. Additionally, the absence of a formal turnover of accounting and procurement records following personnel changes limited the availability of information necessary to identify a complete and accurate population for testing. Effect: Because no procurement transactions were tested, the auditors were unable to determine whether Kagman Community Health Center, Inc. complied with federal procurement requirements, including competition, documentation, and suspension and debarment verification. This increases the risk of noncompliance with federal procurement standards and weakens internal controls over compliance with federal award requirements. Recommendation: Kagman Community Health Center, Inc. should strengthen internal controls over federal procurement compliance by: 1. Ensuring procurement transactions are properly identified, documented, and tracked by federal program. 2. Maintaining complete procurement records, including evidence of competition and suspension and debarment verification. 3. Reconciling procurement-related expenditures to the SEFA and accounting records to allow identification of a complete population for compliance testing. 4. Establishing formal turnover and record-retention procedures to ensure continuity of procurement documentation during personnel transitions. Views of the Officials: Kagman Community Health Center, Inc.’s response is documented in the corrective action plan.

Corrective Action Plan

Corrective Action Plan Action Item Responsible Party Monitoring Require that procurement transactions be properly identified and tracked by federal program to ensure completeness and traceability. CFO / Procurement Staff Monthly review Maintain complete procurement documentation, including records of competition, procurement method, and verification of suspension and debarment in accordance with federal requirements. CFO / Procurement Department Periodic internal review Reconcile procurement-related expenditures to the SEFA and underlying accounting records to ensure a reliable population for compliance testing. CFO Documented reconciliation In FY 2026, management developed and implemented a formal Records Retention Policy to ensure that accounting records, supporting documentation, and organizational records are properly maintained and retained in accordance with applicable regulatory and audit requirements CFO Management oversight Implement supervisory review of procurement activity to ensure compliance with federal procurement requirements. CFO / Board Finance Committee Quarterly review ________________________________________ Management Response Management notes that no additional federal grants, other than the HRSA Section 330 program grant (Assistance Listing 93.224), were received in FY2025 or FY2026. Prior management did not provide a reconciled SEFA schedule for earlier reporting periods, which contributed to the documentation limitations identified during the audit. Beginning in FY2026, management has developed a detailed SEFA tracking schedule for the HRSA Section 330 grant that identifies the date federal funds were drawn down, the amount received, the related expenditures, and the corresponding disbursement dates. This schedule is maintained to improve reconciliation between drawdowns, expenditures, and the general ledger and to ensure documentation is readily available for audit and compliance purposes. In FY2026, management implemented an updated and comprehensive set of policies and procedures designed to strengthen internal controls and promote consistent, standardized accounting and administrative practices. These updates establish clearer documentation requirements, defined responsibilities, and improved oversight to ensure compliance with applicable regulations and the safeguarding of organizational records and financial information. ________________________________________ Responsible Official: Chief Financial Officer Expected Completion Date: FY 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1179022 2023-006
    Material Weakness Repeat
  • 1179023 2023-007
    Material Weakness Repeat
  • 1179024 2023-008
    Material Weakness Repeat
  • 1179025 2023-009
    Material Weakness Repeat
  • 1179027 2023-011
    Material Weakness Repeat
  • 1179028 2023-011
    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) $2.49M
93.225 NATIONAL RESEARCH SERVICE AWARDS HEALTH SERVICES RESEARCH TRAINING $139,026
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $72,668