Finding 1204849 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396483
Organization: Nami Chicago (IL)
Auditor: APRIO LLP

AI Summary

  • Core Issue: NAMI Chicago's procurement controls are ineffective, leading to potential noncompliance with federal requirements.
  • Impacted Requirements: The procurement policy does not meet 2 CFR §200.318 standards for written procedures and vendor eligibility.
  • Recommended Follow-Up: Management should revise the procurement policy to ensure compliance with Uniform Guidance.

Finding Text

Finding 2025-002: Procurement - Significant Deficiency. Program name: Substance Abuse and Mental Health Services Projects of Regional and National Significance. Assistance Listing: 93.243. Federal award number: 45CBB04530. Federal award year: 7/1/2024 - 6/30/2025. Federal awarding agency: U.S. Department of Health and Human Services. Criteria - 2 CFR §200.318 requires written procurement procedures and awarding contracts only to responsible contractors, with sufficient procurement documentation. Condition - NAMI Chicago’s procurement controls were not designed or operating effectively. The procurement policy does not fully comply with Uniform Guidance. Cause - Management has not fully updated procurement policies or implemented consistent controls over vendor eligibility verification and contract authorization. Effect - There is an increased risk of noncompliance with federal procurement requirements, including contracting with ineligible vendors or entering into unauthorized agreements, which could result in questioned or disallowed costs. Questioned costs - None identified. Identification of Repeat Findings - No. Recommendation - Management should update the procurement policy to align with Uniform Guidance. Management response - See corrective action plan.

Corrective Action Plan

NAMI Chicago acknowledges the finding and has revised the finance policy as of January 1, 2026 to clearly define micro-purchase thresholds and procedures for micropurchases, simplified acquisition thresholds and procedures for simplified acquisitions, formal procurement methods for use when transactions exceed acquisition threshold and noncompetitive procurement methods. Management will monitor procurement activity for compliance with the updated policy.

Categories

Eligibility Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1204848 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $2.31M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $523,338
16.745 CRIMINAL AND JUVENILE JUSTICE AND MENTAL HEALTH COLLABORATION PROGRAM $208,738
93.997 ASSISTED OUTPATIENT TREATMENT $37,802
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $23,333