Finding Text
Federal Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Federal Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) and Consolidated Health Centers Grant AL Number: 10.557 and 93.224 & 93.527 Award Period: 4/1/25 - 3/31/26 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over procurement we noted the Organization did not have a Small or Micro-Purchase Threshold in place within their procurement policy. We also noted two instances in which the Organization was unable to locate documentation that agreements with vendors related to the infrastructure project included the Build America, Buy America domestic preference provisions in each agreement or that the Organization obtained a BABA (Build America, Buy America) waiver prior to contracting with the vendor. Effect Noncompliance results in possible federal funds provided to ineligible vendors. Questioned Costs None identified. Cause Management oversight in which the procurement policy did not meet the federal requirements. Recommendation We recommend the Organization update its procurement policy to be in line with the federal requirements. Views of Responsible Officials The Organization will update the Procurement and Purchasing Policy and Procedure to include a Small and Micro-Purchase Threshold and the BABA requirements. The Organization will have this policy and procedure update completed by July 13, 2026.