Finding Text
PROCUREMENT AND SUSPENSION AND DEBARMENT – SMALL, FORMAL, AND NONCOMPETITIVE PROCUREMENTS Finding Type: Significant Deficiency in Internal Controls over Compliance ALN and Program Title: 93.676 – Unaccompanied Alien Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Liberty Wilderness Crossroads Camp Contract Number: 90ZU0501 Criteria: 2 CFR 200 Subpart D of the Uniform Guidance outlines standards for procurement transactions made with federal funds. Additionally, 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The auditor tested 4 small, formal, and noncompetitive procurements which were also covered transactions (this was not a statistically valid sample). For all procurements tested, all necessary documentation of the procurement process was not maintained, the procurement method used was incorrect or there was no documented justification for the procurement to be noncompetitive, and there was no evidence the Organization verified that vendor was not suspended or debarred. For 3 procurements, the original procurement was done many years ago and management has not changed vendors and has not documented a reasoning for this. Cause: The Organization’s policies and procedures for purchasing do not align with Uniform Guidance. Additionally, the existing procurement policies were not followed. Effect: Procurements were potentially not made in compliance with Uniform Guidance. Questioned Costs: None Recommendation: We recommend the Organization update its policies and procedures for purchasing and suspension and debarment to align with Uniform Guidance or other requirements, whichever are more restrictive, and maintain all necessary documentation of the procurement process for purchases. We also recommend management re-evaluate vendors periodically and document any reasoning for not performing a new procurement for the goods or services. Views of Responsible Officials and Planned Corrective Actions: See management’s response and Corrective Action Plan on page 55.