Finding Text
Finding 2025-002 Type of Finding: Material weakness in internal control over compliance and instance of immaterial noncompliance Compliance requirement: Procurement and suspension and debarment Criteria: Uniform Guidance procurement standards require nonfederal entities to use documented procurement procedures and maintain procurement policies and procedures that conform to applicable federal requirements for procurement transactions under a federal award. Condition: Willamette Health Council did not have written procurement policies and procedures that conform to, or contain all required elements of, the Uniform Guidance procurement standards. Although Willamette Health Council did not have compliant written procurement policies, there were no procurements tested (and none identified by management) with expenditures exceeding the applicable micro-purchase threshold during the audit period. Cause: Willamette Health Council had not established and implemented formal, written procurement policies and procedures aligned with Uniform Guidance requirements, including periodic review and updates to ensure continued compliance. Effect / Potential Effect: While no procurements exceeding the micro-purchase threshold were identified during the audit period (and therefore the instance of noncompliance is considered immaterial), the absence of compliant written procurement policies represents a deficiency in the design of internal control over compliance. Without properly designed procurement policies and procedures, there is an increased risk that future procurement transactions may not be conducted in accordance with the Uniform Guidance and that noncompliance may not be prevented, detected, or corrected on a timely basis. Accordingly, this condition is considered a material weakness in internal control over compliance. Questioned Costs: None. Context/Perspective: Per review of Willamette Health Council expenditure records, procurement transactions during the period totaled $18,683; and all of which were under $10,000 thus, the micropurchase threshold applied. Repeat Finding: Not applicable. There was no prior year audit. Recommendation: We recommend that Willamette Health Council develop, approve, and implement written procurement policies and procedures that conform to the Uniform Guidance procurement standards outlined in 2 CFR §200.318 through §200.327. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.