Finding Text
Assistance Listing Number 93.576, Refugee and Entrant Assistance Discretionary Grants, U.S. Department of Health and Human Services, FAIN 90RP0121, Award Year 2023, Passed Through by the United States Conference of Catholic Bishops Criteria or Specific Requirement – Procurement, Suspension, and Debarment – 2 CFR § 200.317–.327; 2 CFR § 200.214 Condition – Catholic Charities is required to have and use documented procurement procedures, consistent with federal, state, and local laws and regulations, for the acquisition of property and services required under a federal award or subaward and for determining an entity is not suspended or debarred before entering into a covered transaction. Additionally, Catholic Charities is required to maintain support that documents the full history of procurement transactions. Cause – Catholic Charities’ procurement procedures are not tailored to include considerations of the Uniform Guidance, including methods of procurement to be followed, the thresholds at which certain procedures are necessary, provisions regarding conflicts of interests, procedures to ensure vendors are not debarred or suspended from participation in federal assistance programs or activities, and maintenance of documentation related to procurement transactions. Effect – Catholic Charities’ procurements were not conducted in accordance with federal laws and regulations, and Catholic Charities’ procurement policy does not meet federal requirements. In addition, the entity did not have a policy to check suspension and debarment for contracts using federal awards. Questioned Costs – None Context – Two purchases exceeded the small purchase threshold for this program during 2023, one of which was also above the simplified acquisition threshold. Neither had documentation supporting price or rate quotations, and neither had documentation that procedures were performed to ensure vendors were not debarred, suspended, or otherwise excluded from participation in federal assistance programs or activities. Identification as a Repeat Finding, if applicable – N/A Recommendation – Catholic Charities should revise its procurement policy to ensure procurements are conducted in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions – Management concurs with the finding, and changes to Catholic Charities’ procurement policy are being considered. Catholic Charities performed a retroactive review of both procurements and determined that they both would have qualified as noncompetitive procurements under 2 CFR § 200.320(c) due to both the specialized nature of the services provided and the public exigency presented by the nature of the Afghan refugee program. Management also determined that the lack of documentation related to these transactions is in part related to significant turnover occurring since this program was active.