Finding 1218022 (2024-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2026-06-20
Audit: 404207
Organization: Papa Ola Lokahi (HI)
Auditor: KKDLY LLC

AI Summary

  • Core Issue: The Organization failed to follow required competitive procurement processes for contracts, violating Uniform Guidance standards.
  • Impacted Requirements: Noncompliance with 2 CFR §200.320 regarding procurement methods and documentation for noncompetitive contracts.
  • Recommended Follow-Up: Update policies to align with Uniform Guidance and maintain detailed records of procurement history to ensure compliance.

Finding Text

Material Weakness Finding No. 2024-003: Procurement Policies U.S. Department of Health and Human Services Substance Abuse and Mental Health Services Federal Assistance Listing Number 93.243. U.S. Department of Health and Human Services Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. Criteria The Uniform Guidance 2 CFR §200.320 sets forth the methods of procurement to be followed in the acquisition of property or services required under a Federal award or subaward, which includes formal purchase methods such as proposal or bids when the value of the property or services under a Federal financial assistance award exceeds a certain threshold, as defined. Furthermore, 2 CFR §200.320(c) provides specific circumstances in which noncompetitive procurement can be used. Condition During our audit, we noted that the Organization entered into contracts with entities which were subject to a formal purchase method, for which competitive processes for selection were not performed, nor was documentation of the specific criteria of 2 CFR §200.320(c) met to support noncompetitive procurements maintained. Cause Management had not updated its policies and procedures to incorporate certain pertinent sections of the procurement standards of the Uniform Guidance. Effect The lack of procurement standards in accordance with the Uniform Guidance may result in allowable cost issues. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediately previous audit as Finding No. 2023-003. Recommendation We recommend that the Organization incorporate and adhere to the procurement standards of the Uniform Guidance to its policies and procedures manual to ensure compliance with Federal standards, including 2 CFR §200.318(h) which stipulates that sufficient detail of the history of the procurement must be maintained, including the selection of the contractor.

Corrective Action Plan

Views of Responsible Officials and Corrective Action While the Organization concurred with the prior year (2023-003) and current year renumbered recommendation (2024-003), the Organization notes the corrective actions that have been implemented, specifically related to the incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h); and development of a comprehensive Health Resources & Services Administration (HRSA) group of related policies and procedures. A. Financial Policies – May 2025. While the Organization initially prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024, by May 2025, the Organization completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Simultaneous to the policy work described above, several processes to guide and align procurement practices, throughout the Organization, was initiated, including the use of MTPF, Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal, and to date implementation of the processes continue. C. HRSA Policies – July 2025. By July 2025, the Organization developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. In August 2025, the Board was provided policies developed within the Organization’s policy framework, including the above policies. The current practices of the Organization, to the present period of the report dated June 17, 2026, is consistent with such developed policies.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1218007 2024-002
    Material Weakness Repeat
  • 1218008 2024-002
    Material Weakness Repeat
  • 1218009 2024-002
    Material Weakness Repeat
  • 1218010 2024-002
    Material Weakness Repeat
  • 1218011 2024-002
    Material Weakness Repeat
  • 1218012 2024-002
    Material Weakness Repeat
  • 1218013 2024-002
    Material Weakness Repeat
  • 1218014 2024-002
    Material Weakness Repeat
  • 1218015 2024-003
    Material Weakness Repeat
  • 1218016 2024-003
    Material Weakness Repeat
  • 1218017 2024-003
    Material Weakness Repeat
  • 1218018 2024-003
    Material Weakness Repeat
  • 1218019 2024-003
    Material Weakness Repeat
  • 1218020 2024-003
    Material Weakness Repeat
  • 1218021 2024-003
    Material Weakness Repeat
  • 1218023 2024-004
    Material Weakness Repeat
  • 1218024 2024-004
    Material Weakness Repeat
  • 1218025 2024-004
    Material Weakness Repeat
  • 1218026 2024-004
    Material Weakness Repeat
  • 1218027 2024-004
    Material Weakness Repeat
  • 1218028 2024-004
    Material Weakness Repeat
  • 1218029 2024-004
    Material Weakness Repeat
  • 1218030 2024-004
    Material Weakness Repeat
  • 1218031 2024-005
    Material Weakness Repeat
  • 1218032 2024-005
    Material Weakness Repeat
  • 1218033 2024-005
    Material Weakness Repeat
  • 1218034 2024-005
    Material Weakness Repeat
  • 1218035 2024-005
    Material Weakness Repeat
  • 1218036 2024-005
    Material Weakness Repeat
  • 1218037 2024-005
    Material Weakness Repeat
  • 1218038 2024-005
    Material Weakness Repeat
  • 1218039 2024-006
    Material Weakness Repeat
  • 1218040 2024-006
    Material Weakness Repeat
  • 1218041 2024-006
    Material Weakness Repeat
  • 1218042 2024-006
    Material Weakness Repeat
  • 1218043 2024-006
    Material Weakness Repeat
  • 1218044 2024-006
    Material Weakness Repeat
  • 1218045 2024-006
    Material Weakness Repeat
  • 1218046 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1.24M
84.362 NATIVE HAWAIIAN EDUCATION $710,867
93.932 NATIVE HAWAIIAN HEALTH CARE SYSTEMS $281,520
93.387 NATIONAL AND STATE TOBACCO CONTROL PROGRAM $94,587
45.311 NATIVE AMERICAN AND NATIVE HAWAIIAN LIBRARY SERVICES $59,054
93.837 CARDIOVASCULAR DISEASES RESEARCH $21,218
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $20,590
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION€™S HEALTH $18,362
93.185 IMMUNIZATION RESEARCH, DEMONSTRATION, PUBLIC INFORMATION AND EDUCATION TRAINING AND CLINICAL SKILLS IMPROVEMENT PROJECTS $15,770