Finding 1236324 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-24

AI Summary

  • Core Issue: The organization lacks a compliant procurement policy, failing to meet federal requirements outlined in 2 CFR 200.318.
  • Impacted Requirements: Key elements such as competition, cost analysis, and documentation are missing from the current policy.
  • Recommended Follow-Up: Develop and implement a new procurement policy that aligns with federal standards to avoid compliance risks and protect funding opportunities.

Finding Text

Federal Agency: Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.243 Federal Award Identification Number and Year: 1H79SM087513-01 - 2024 Award Period: September 30, 2023 through September 29, 2027 Type of Finding: • Other Matters Criteria or specific requirement: According to 2 CFR 200.318, non-federal entities must have and use documented procurement procedures that reflect applicable state and local laws and regulations, and conform to federal law and the standards identified in 2 CFR 200.318 through 2 CFR 200.327. Condition: During our review of the organization's procurement processes, it was noted that the organization does not have a procurement policy that complies with federal requirements. Specifically, the policy does not address key elements such as competition, cost or price analysis, and documentation requirements as outlined in federal regulations. Questioned costs: None Context: Policies exist, but do not meet requirements. There are no requirements to retain documentation related to comparison or analysis prior to purchase or procurement. Cause: The absence of a compliant procurement policy appears to be due to a lack of awareness of the specific federal requirements and the absence of a formal process to review and update organizational policies to ensure compliance. Repeat Finding: Yes Effect: Without a procurement policy that complies with federal requirements, the organization is at risk of non-compliance with grant conditions, which could lead to questioned costs, potential disallowance of expenditures, and jeopardize future funding opportunities. Recommendation: We recommend that the Organization develop and implement a procurement policy that complies with federal requirements, including provisions for competition, cost or price analysis, and proper documentation. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Substance Abuse and Mental Health Services Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: During our review of the organization's procurement processes, it was noted that the organization does not have a procurement policy that complies with federal requirements. Specifically, the policy does not address key elements such as competition, cost or price analysis, and documentation requirements as outlined in federal regulations. We recommend that the Organization develop and implement a procurement policy that complies with federal requirements, including provisions for competition, cost or price analysis, and proper documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has reviewed the federal law and standards identified in 2 CFR 200.318 through 2 CFR 200.327. A procurement policy that aligns with these federal requirements is currently being developed. Name(s) of the contact person(s) responsible for corrective action: Lynn Lowrie Planned completion date for corrective action plan: Policy has been drafted and is under internal review. This will be finalized during the November 2026 Board Meeting.

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $968,060
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $263,108
10.555 NATIONAL SCHOOL LUNCH PROGRAM $2,584