Finding 1205430 (2025-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-31

AI Summary

  • Core Issue: Misclassification of procurements as sole source without proper justification and insufficient documentation of quotes.
  • Impacted Requirements: Noncompliance with Uniform Guidance and TxGMS procurement standards, risking disallowed costs and increased scrutiny.
  • Recommended Follow-Up: Strengthen procurement controls by implementing supervisory reviews and standardized documentation practices for procurement methods and quotes.

Finding Text

Federal Program: Maternal, Infant and Early Childhood Home Visiting Grant (including COVID-19) - ALN 93.870; Federal Award # 24853633; passed through Texas Department of Family and Protective Services; passed through Texas Health and Human Services Commission. State Programs: Texas Home Visiting (THV) Program Grant - Award # 24853633; direct funding from Texas Department of Family and Protective Services. Texas Home Visiting (THV) Program Grant - Award # 24853633; direct funding from Texas Health and Human Services Commission. Criteria: Uniform Guidance (2 CFR 200.318 - 200.327) and TxGMS (General Procurement Standards) requires non-federal entities to ensure procurements are conducted using appropriate methods based on dollar thresholds and retain supporting documentation, including an adequate number of quotations from qualified sources for simplified acquisitions (formerly small purchases). Condition /Context: During testing of procurement transactions, two instances were identified in which management incorrectly classified procurements as sole source without adequate justification in accordance with Uniform Guidance or TxGMS, as applicable. Additionally, in these two instances tested, management did not retain sufficient documentation of quotes to support that procurements were conducted in compliance with simplified acquisition requirements (formerly small purchase). Questioned Costs: None Effect: Noncompliance with procurement requirements of Uniform Guidance and TxGMS, which increases the risk that purchases were not conducted in a manner providing full and open competition and may result in disallowed costs or increased scrutiny from grantor agencies. Cause: The condition resulted from inadequate procurement controls, including a lack of formalized review procedures for determining and documenting appropriate procurement methods. This resulted in United Way ATX not retaining the required supporting documentation for competitive procurements. Recommendations: United Way ATX should strengthen procurement controls by performing supervisory review of procurement classification and supporting documentation prior to approval and payment. In addition, management should implement standardized documentation requirements, including identification of procurement methods used and retention of quotes or bids for applicable procurements.

Corrective Action Plan

Planned Corrective Action: Management will strengthen procurement policies, procedures, and documentation practices to ensure compliance with Uniform Guidance (2 CFR 200.318–200.327) and TxGMS general procurement standards. Actions will include: updating the procurement policy to clarify procurement methods and dollar thresholds; adopting a standardized procurement justification template for sole source determinations that requires documented rationale and supervisory approval; implementing a required procurement file checklist that documents the procurement method used, vendor selection process, quotes or bids obtained, and retained supporting documentation; instituting supervisory review and sign off of procurement classification and supporting documentation prior to award approval and payment; providing targeted training for Programs, Finance, and Procurement staff on procurement rules, sole source justification, and simplified acquisition documentation requirements; and performing a retrospective review of the two identified procurements to complete or document required supporting evidence and remediate any gaps. Finance will perform periodic testing of procurement files to verify adherence to the updated procedures and report findings to management and the Audit Committee. Responsible Parties: Kyle Bolls, Controller Ryan Parks, CFO Estimated Completion Date: September 30, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1205428 2025-004
    Material Weakness Repeat
  • 1205429 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.870 Maternal, Infant, and Early Childhood Home Visiting Grant Program $642,026
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $641,420
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $310,353
93.778 GRANTS TO STATES FOR MEDICAID $239,821
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $141,868
93.434 EVERY STUDENT SUCCEEDS ACT/PRESCHOOL DEVELOPMENT GRANTS $121,125
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $50,014
93.870 COVID-19 Maternal, Infant, and Early Childhood Home Visiting Grant Program $48,455
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $35,012
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $4,496
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $1,395