Finding 1216965 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-08
Audit: 403260
Organization: Clinica Sierra Vista (CA)
Auditor: DZA PLLC

AI Summary

  • Core Issue: The Organization failed to maintain required documentation for competitive price quotations on purchases above the micro-purchase threshold, violating procurement policies.
  • Impacted Requirements: Compliance with Title 2 CFR 200.320 is necessary for federal awards, which mandates proper procurement methods and documentation.
  • Recommended Follow-Up: Ensure all transactions over the micro-purchase threshold have supporting documentation for competitive procurement to comply with federal guidelines.

Finding Text

2025-003 Procurement Program Information Federal Organizations U.S Department of Health and Human Services U.S Department of Agriculture (passed through California Department of Public Health) Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award Numbers H80CS00540-23, H8GCS48292, H8LCS51370, 22-10237 A05 Criteria Entities receiving federal awards must have and use their documented procurement policies. Title 2 CFR 200.320 outlines the acceptable methods of procurement and establishes the maximum thresholds allowed. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Condition The Organization did not maintain documentation that competitive price quotations or bids performed, as required by policy and the Uniform Guidance for purchases above the micro purchase threshold. This finding appears to be a systemic issue. Cause Management did not follow its established procurement policy and documentation was not maintained evidencing its compliance with the policy. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $0. Although the auditee did not retain documentation of required competition (such as bids or price quotes) for contracts, as required under the entity’s written procurement procedures and the Uniform Guidance procurement standards in 2 CFR part 200, our testing indicated that the costs charged to the federal program under this contract were otherwise allowable under the applicable cost principles, adequately supported by other documentation, and reasonable in amount. Context We tested procurement transactions from each program. Of these transactions, four of thirteen tested under assistance listing numbers 93.224 and 93.527, and six of twenty-five tested under assistance listing number 10.557, were missing evidence of proper competitive procurement procedures being performed. Recommendation We recommend the Organization retain supporting documentation of competitive procurement for all transactions greater than the micro-purchase threshold when the expenditures will be charged to a federal award. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

Corrective Action Plan

2025-003 Procurement Corrective action planned: CSV will enforce its procedure policy that all competitive procurement transactions above the micro-purchase threshold, when expenditures are charged to a federal award, must have complete supporting documentation retained for at least four years after final payment, in accordance with 2 CFR 200.320. This will be accomplished by providing training for procurement, finance, and administrative staff on: • Recognizing when a transaction exceeds the threshold. • Collecting and organizing supporting documentation. • Understanding retention periods and storage requirements. The Procurement Manager shall oversee compliance with the threshold and retention requirements. CSV shall conduct periodic audits to: • Review procurement files for completeness and compliance with retention requirements. • Identify gaps or missing documentation and correct them promptly. • Document audit findings and corrective actions. Anticipated completion date: June 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1216959 2025-002
    Material Weakness Repeat
  • 1216960 2025-002
    Material Weakness Repeat
  • 1216961 2025-002
    Material Weakness Repeat
  • 1216962 2025-003
    Material Weakness Repeat
  • 1216963 2025-003
    Material Weakness Repeat
  • 1216964 2025-003
    Material Weakness Repeat
  • 1216966 2025-004
    Material Weakness Repeat
  • 1216967 2025-004
    Material Weakness Repeat
  • 1216968 2025-004
    Material Weakness Repeat
  • 1216969 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $22.75M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $9.13M
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $611,514
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $510,152
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $381,375
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $373,833
93.917 HIV CARE FORMULA GRANTS $251,436
14.267 CONTINUUM OF CARE PROGRAM $185,987
93.153 COORDINATED SERVICES AND ACCESS TO RESEARCH FOR WOMEN, INFANTS, CHILDREN, AND YOUTH $152,314
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $118,953
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $109,230
93.788 OPIOID STR $26,851
93.332 COOPERATIVE AGREEMENT TO SUPPORT NAVIGATORS IN FEDERALLY-FACILITATED EXCHANGES $25,171