Finding 1215473 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-05-26

AI Summary

  • Core Issue: HAH did not follow procurement policies as required by Uniform Guidance 2 CFR 200.318, failing to obtain necessary bids for certain vendors.
  • Impacted Requirements: Non-compliance with procurement procedures for goods and services, particularly for purchases exceeding the micro-purchases threshold.
  • Recommended Follow-Up: HAH should create an updated procurement policy and assign a person to review all relevant purchases and documentation before approval.

Finding Text

Federal Procurement Regulations Significant Deficiency U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES ALN #: 93.224 - Health Centers Program and 93.527 - Grants for New and Expanded Services under the Health Center Program Federal Award Identification #: H80CS00111 Condition: During the Health Centers Program audit, it was noted that HAH did not follow their procurement policies as required by the Uniform Guidance 2 CFR 200.318. Criteria: 2 CFR 200.318 Questioned Costs: $0 Context: During the audit, it was noted that while the majority of program expenditures are salary and benefits, HAH did not follow their policies for procurement for other goods and services, and did not obtain multiple bids or sole source justification for three out of eight vendors selected for testing that exceeded the micro-purchases threshold. Cause: Turnover at HAH, who separated from the parent entity in FY24 resulting in changes in procedures. Effect: Lack of internal control to ensure program requirements Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that HAH establish an updated procurement policy and designate an individual to review all purchases over the micro-purchases threshold and review procurement documentation to ensure it is sufficient before expenses are approved for payment. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Federal Procurement Regulations Planned Corrective Action: During the audit period, HAH experienced significant organizational transition, including separation from its parent organization, turnover in key administrative and finance positions, and the rebuilding of internal financial operations and controls. These circumstances contributed to inconsistent application and documentation of procurement procedures. To address this deficiency and prevent recurrence, HAH worked with HRSA Technical Assistance resources to develop an enhanced procurement policy and procedure, which is scheduled for Board approval in May 2026. In the interim, HAH has reinforced procurement requirements through staff training and communication regarding federal procurement standards. Additionally,management has implemented ongoing monitoring and compliance reviews of procurement activities to ensure adherence to policy requirements, including appropriate bid documentation and sole source justification when applicable Person Responsible for Corrective Action Plan: Donald McGruder, CFO Anticipated Date of Completion: Resolved

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1215472 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $7.42M
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $861,300
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $335,171
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $215,094
93.917 HIV CARE FORMULA GRANTS $199,054
14.267 CONTINUUM OF CARE PROGRAM $92,443
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $37,777
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $31,970
93.247 ADVANCED NURSING EDUCATION WORKFORCE GRANT PROGRAM $20,000
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $18,890
93.924 RYAN WHITE HIV/AIDS PROGRAM DENTAL REIMBURSEMENT AND COMMUNITY BASED DENTAL PARTNERSHIP GRANTS $18