Finding 1239143 (2025-002)

Finding 2025-002 - Procurement and Suspension and Debarment Information on the federal program: Federal Agency: United States Department of Health and Human Services ALN: 93.889 National Bioterrorism Hospital Preparedness Program Pass-Through Grantor: Illinois Department of Public Health and Illinois Health and Hospital Association Pass-Through Award Number: 57280009M; 67280009N; 47280009L; 47280007L; 57280009M Pass-Through Award Period: 7/1/2023 to 6/30/2026 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions Section III – Federal Award Findings and Questioned Costs (continued) of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Section 200.318(j) states, “The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The System did not retain procurement records documenting the appropriate criteria required by Section 200.318(j). Cause: The System did not have sufficiently designed internal controls to ensure that procurement records are retained in accordance with Section 200.318(j). Effect or potential effect: Federal procurement and suspension and debarment transactions may not be in compliance with federal regulations. Questioned Costs: $175,509 Context: We tested six samples representing 100% of the procurement population relating to the federal program for the period January 1, 2025 through December 31, 2025. For all six items, there was no evidence of procurement records supporting the type of procurement method used. The total National Bioterrorism Hospital Preparedness Program expenditures reported on the Schedule are $882,827 for the year ended December 31, 2025. The procurement population related to this federal program was $175,509. Section III – Federal Award Findings and Questioned Costs (continued) Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The System should implement more robust internal controls to ensure that accurate procurement records are maintained. Views of responsible officials: Management agrees with the finding and will strengthen internal controls over procurement documentation. The Program team will receive refresher training to ensure required records for federally funded purchases are complete, properly maintained, and retained in accordance with Federal requirements. Management will conduct periodic monitoring to verify compliance and address any deficiencies timely.