Finding 1229183 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-09
Audit: 410692
Organization: All Nations Health Center, Inc. (MT)
Auditor: REDW LLC

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance with procurement regulations, specifically the lack of documentation for full and open competition.
  • Impacted Requirements: Noncompliance with 2 CFR 200.319(a) regarding procurement processes, including failure to verify contractor eligibility.
  • Recommended Follow-Up: Provide training for procurement personnel, ensure understanding of policies, and maintain regular communication about updates to procurement procedures.

Finding Text

2025-002 — Procurement, Suspension, and Debarment – Significant Deficiency in Internal Controls Over Compliance and Noncompliance Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Urban Indian Health Services ALN number: 93.193 Award years and number: 75H70921C00004 Criteria: In accordance with 2 CFR 200.319(a), it is required that “all procurement transactions under the federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320.” Condition: Auditor reviewed one procurement sample. During our review, no documentation was provided to demonstrate that full and open competition was maintained in the procurement process, such as advertisement for bids, quotes obtained, evaluation of price, or basis for selecting the contractor. In addition, no documentation was provided indicating proper verification that the contractor was not debarred, suspended, or otherwise excluded. A subsequent check was conducted, indicating the contractor was not debarred, suspended or excluded. Questioned Costs: None. Cause: Although the Center maintains sufficient procurement policy, program personnel did not adequately follow the procurement policy. The inconsistency in the adherence to the procurement policy is attributed to the lack of monitoring. Effect: The failure to adhere to established procurement policy increases the risk of noncompliance with federal regulations. Auditor’s Recommendations: We recommend providing comprehensive training to all personnel involved in review and approval over procurement on the procurement process. Ensure all employees understand the importance of adhering to procurement policies and the benefits of a streamlined, centralized approach. Regular communication and updates on any changes in procurement procedures should be maintained. Management Response: All Nations will regularly review its purchasing policies with Finance and Leadership staff and members of its Board of Directors’ Audit and Finance Committee to ensure that proper procedures and documentation are followed and to update purchasing policies when changes are required.

Corrective Action Plan

Before reviewing and updating it Fiscal Policies, including its purchasing and procurement policies, All Nations Finance Director and CEO will ensure that finance staff, the Audit and Finance Committee, and its accounting partner know how to adhere to and have a thorough understanding of the importance of complying with its purchasing and procurement policies.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1229180 2025-001
    Material Weakness Repeat
  • 1229181 2025-001
    Material Weakness Repeat
  • 1229182 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.193 URBAN INDIAN HEALTH SERVICES $734,097
93.283 CENTERS FOR DISEASE CONTROL AND PREVENTION INVESTIGATIONS AND TECHNICAL ASSISTANCE $279,434
93.653 INDIAN HEALTH SERVICE DOMESTIC VIOLENCE PREVENTION PROGRAMS $201,109
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $139,474
93.237 SPECIAL DIABETES PROGRAM FOR INDIANS DIABETES PREVENTION AND TREATMENT PROJECTS $111,907
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $19,636