Finding Text
Finding 2025-001: Significant Deficiency – Procurement Documentation and Suspension/Debarment Verification Federal Grantor: U.S Department of Health and Human Services Compliance Requirement: Procurement, Suspension and Debarment Condition: CFILC did not retain sufficient procurement documentation to support compliance for certain purchases tested. Specifically, documentation supporting the evaluation process, sole-source procurement justification, and SAM.gov verification for suspended and debarred parties was not available for review. Criteria: Federal procurement standards require non-federal entities to maintain records sufficient to detail the history of procurement transactions, including the rationale for the method of procurement, contractor selection, basis for contract price, and verification that vendors are not suspended or debarred from participating in federally funded programs. Cause: CFILC’s procurement record retention procedures did not ensure that procurement files consistently included documentation supporting bid analyses, sole-source determinations, procurement evaluations, and SAM.gov verification procedures. Effect: The lack of complete procurement documentation limits CFILC’s ability to demonstrate compliance with federal procurement requirements and may result in questioned costs or noncompliance findings. Recommendation: We recommend that CFILC strengthen procurement documentation and record retention procedures to ensure procurement files consistently include documentation supporting vendor evaluations, bid analyses, sole-source justifications, SAM.gov verification, and related procurement decision-making records. In addition, staff responsible for procurement activities should be trained on federal procurement documentation requirements to ensure compliance is adequately supported. Response: We concur with the finding and have strengthened our procurement documentation procedures.