Finding Text
Assistance Listing, Federal Agency, and Program Name 93.493, U.S. Department of Health and Human Services, Congressional Directives Federal Award Identification Number and Year CE1HS52674 & CE1HS53568 2025 Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria The Corporation is required to maintain and follow written procurement procedures that comply with Uniform Guidance procurement standards, including the requirements in 2 CFR 200.317-200.327 regarding procurement methods and documentation of the history of procurement transactions. The Corporation is also required to comply with suspension and debarment requirements, including verification procedures required under 2 CFR 200.212, 2 CFR 200.318(h), 2 CFR 180.300, and 48 CFR 52.209-6. The requirements state that procurements paid with federal funds are supported by documentation showing the method of procurement, the basis for contractor selection, and compliance with suspension and debarment requirements. Condition The Corporation’s procurement and suspension/debarment policies and procedures were not in conformance with Uniform Guidance requirements. In addition, procurement records for the items tested did not contain sufficient documentation to support the procurement method used, the basis for contract selection, or compliance with suspension and debarment requirements. Questioned Costs $1,350,000 If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A Identification of How Questioned Costs Were Computed The questioned costs represent activity reported on the SEFA incurred under contracts not in compliance with federal procurement standards. Context For both contracts tested, no records were available to support the procurement method, contractor selection, or performance of required suspension/debarment verification procedures. Based on the items tested, the issue was not an isolated documentation exception but reflected a control and compliance deficiency affecting the compliance areas of procurement and suspension/debarment. Cause and Effect The Corporation did not have sufficiently developed procurement, suspension, and debarment policies and procedures aligned to Uniform Guidance requirements. As a result, compliance procedures over these areas were not adequately established or performed. Without Uniform Guidance-compliant procurement policies, required procurement history documentation, and evidence of suspension/debarment verification, the Corporation cannot demonstrate that contracts charged to the federal award were procured in accordance with federal requirements. This increases the risk of noncompliance with procurement and suspension/debarment requirements and resulted in material noncompliance over the major program. Recommendation The Corporation should update and formally adopt written procurement, suspension, and debarment policies and procedures to conform to Uniform Guidance requirements and should implement procedures to ensure those policies are consistently followed and documented for all federally funded procurements. Views of Responsible Officials and Planned Corrective Actions The Corporation concurs with the finding. The Corporation will update and formally adopt written procurement, suspension, and debarment policies and procedures to conform to Uniform Guidance requirements and implement procedures to ensure those policies are consistently followed and documented for all federally funded procurements.