Finding 19867 (2022-001)

Medical Student Education ALN 93.680 U.S. Department of Health and Human Services 2021?2022 Criteria or Specific Requirement ? Procurement, Suspension, and Debarment, 2 CFR Section 200 Condition ? Documentation supporting that federal procurement requirements were met was not able to be obtained for one of eight purchases selected for testing. Questioned Costs ? $11,110, determined as the dollar amount of invoices not compliant with federal procurement requirements. Context ? Out of the population of 30 purchases that would be subject to procurement requirements during the year, a sample of eight purchases was selected for testing. For one of the purchases tested, documentation supporting that federal procurement requirements were met for the purchase was not able to be obtained. Our sample was not, and was not intended to be, statistically valid. Effect ? Compliance with federal compliance requirements was not able to be verified for this purchase. Cause ? Due to recent turnover in the purchasing department, procurement requirements have not been adequately communicated to the department level. Indication as a Repeat Finding ? N/A Recommendation ? The Center should review its procedures for communicating procurement policies to the department level as well as review federal procurement requirements to ensure what is being done in practice meets these requirements. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the finding and a new Associate Vice President of Procurement was hired in June 2022. Enhanced training will be provided to departments to ensure individuals making purchases with federal funds are educated on federal procurement requirements.