Finding Text
Finding: Procurement and Suspension & Debarment Federal Assistance Listing Number 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery U.S. Department of Health and Human Services Criteria: In accordance with 2 CFR Part 200.318 the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. Condition: The following matters were noted in regards to policies and procedures surrounding compliance with Procurement and Suspension & Debarment: a. The Organization's an internal policy regarding purchases contained thresholds for procurement quotes and bid processes; however, did not align with Uniform Guidance and were less restrictive than Uniform Guidance requirements. b. The Organization had support showing vendor checks on sam.gov; however, the policy did not contain procedures around suspension and debarment checks. c. The Organization's purchasing policy did not contain procedures to look for geographic preferences as required by Uniform Guidance. d. The Organization's conflict of interest policy did not specifically cover the performance of its employees engaged in the selection, award, and administration of contracts as required by Uniform Guidance. Questioned Costs: N/A Context: The Organization's purchasing policy did not contain elements of federal procurement requirements specified by Uniform Guidance. Effect: Lack of policies and procedures could prevent internal controls from detecting noncompliance with a federal requirements. Cause: Purchasing policies did not contain adequate references to Uniform Guidance procurement and suspension and debarment requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Organization update their procurement policy to include updated Unform Guidance thresholds, documented procedures for suspension and debarment checks, and geographic preferences processes. Views of Responsible Officials: The Organization agrees with the finding. See separate auditee document for planned corrective action.