Finding Text
Assistance Listing Number: 93.193 Name of Federal Program: Urban Indian Health Services; COVID-19 Urban Indian Health Services Name of Federal Agency: Department of Health and Human Services Award Period: January 1, 2025 – December 31, 2025 Criteria or Specific Requirement: 2 CFR section 200.318(i) requires a non-federal entity to maintain sufficient records to detail the history of procurement including, but not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Procurements charged to the federal program were not performed in accordance with the procurement standards of the Uniform Guidance. Specifically, the Council did not maintain sufficient documentation to demonstrate that applicable procurement requirements were followed, including evidence of the procurement method used, competition obtained, cost or price analysis when required, and basis for contractor selection. Cause: The Council lacked written policies and procedures to ensure procurements charged to federal awards were performed, documented, reviewed, and approved in accordance with the Uniform Guidance. Procurement policies and procedures have not been designed and implemented that adhere to Uniform Guidance requirements. Effect or Potential Effect: Without sufficient records, the organization cannot demonstrate compliance with Uniform Guidance procurement requirements. This increases the risk of unallowable or unreasonable costs being charged to federal awards and may result in questioned costs or funding agency disallowances. Questioned Costs: $690,921 Context: All general disbursements were considered as a population. Repeat Finding: Yes, thsi is a repeat of Finding 2024-004. Recommendation: Management should implement procedures to ensure that complete procurement documentation is maintained in accordance with 2 CFR §200.318(i). This should include standardized procurement checklists, training for staff involved in purchasing, and periodic internal reviews to confirm that procurement files contain all required documentation. Views of Responsible Officials: Management agrees with the finding and will implement procurement procedures.