Finding Text
Item: 2025-001 Assistance Listing Number: 93.185 Program: Immunization Research, Demonstration, Public Information and Education Training and Clinical Improvement Projects Federal Agency: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: NH23IP922665 Award Year: August 2024 to July 2029 Compliance Requirement: Procurement, Suspension and Debarment Criteria: Per 2 CFR §200.318 - §200.326, non-federal entities must follow procurement procedures that ensure full and open competition and maintain proper documentation of procurement transactions. Additionally, under 2 CFR §200.213, entities must verify that vendors and subrecipients are not suspended or debarred before entering into contracts funded by federal awards. Condition: AIRA did not retain sufficient/updated documentation to support compliance with Uniform Guidance procurement standards. Specifically: • Procurement files lacked evidence of cost/price analysis and vendor selection criteria for purchases exceeding the micro-purchase threshold of $10,000. • The entity did not retain verification records confirming that selected vendors were not suspended or debarred in SAM.gov before contract execution. Questioned Costs: n/a Context: In a population of 35 vendors with purchases in excess of $10,000, we conducted a non-statistical sample of six vendors. In our sample of six vendors, we noted that for two vendors selected and tested, AIRA did not retain sufficient documentation to support compliance with the Uniform Guidance procurement standards. Effect: Failure to maintain proper procurement documentation and verify vendor eligibility increases the risk of noncompliance with federal requirements. This may lead to questioned costs and potential disallowance of federal expenditures. This was deemed to be a significant deficiency in internal control over compliance. Cause: The deficiency appears to result from inadequate internal control over procurement documentation and a lack of formalized procedures ensuring compliance with federal procurement and debarment requirements for a portion of fiscal 2025. In April 2025, AIRA implemented a standardized procurement policy and a formal review process to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds. As these controls were not in place during the entire fiscal year the finding is repeated. Identification as a Repeat Finding: Repeat finding. See 2024-001 Recommendation: Recommendations from prior year’s finding were implemented effectively beginning in April 2025. No additional action necessary. Views of Responsible Officials: Management of the Organization concurs with the finding. See Corrective Action Plan.