Finding 1227221 (2025-002)

Congressional Directives Assistance Listing Number 93.493 U.S. Department of Health and Human Services Criteria or Specific Requirement – Procurement and Suspension and Debarment, 2 CFR Sections 200.214 and 200.318-327 Condition – The Medical Center’s Procurement/Contract Management policy does not fully incorporate Uniform Guidance requirements applicable to federal awards. Cause – The Medical Center has established procurement policies designed primarily for general operational purchasing; however, federal procurement requirements were not formally incorporated into the policy framework. Effect or Potential Effect – The Medical Center could potentially enter into transactions that are not conducted in accordance with the Uniform Guidance requirements. Questioned Costs – N/A Context – The exceptions were identified through evaluation of the entity’s procurement policies and application to federal program requirements. The deficiencies are systemic in nature, affecting the design of controls over procurement and suspension and debarment compliance across applicable transactions. Identification as a Repeat Finding, if applicable – N/A Recommendation – The Medical Center should update procurement policies to explicitly incorporate Uniform Guidance including defining and implementing federally compliant procurement methods and thresholds. The Medical Center should implement controls to ensure consistent application of requirements across all federally funded procurements. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. The Medical Center will revise and update its procurement policies and procedures to incorporate applicable federal procurement requirements under the Uniform Guidance.