Finding 235 (2023-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2023-10-10
Audit: 487
Organization: Sunrise Community Health (CO)

AI Summary

  • Core Issue: The Organization is not complying with procurement and suspension and debarment requirements outlined in 2 CFR Part 200.
  • Impacted Requirements: Lack of a compliant procurement policy and insufficient documentation for procurement methods.
  • Recommended Follow-Up: Update the procurement policy to meet federal requirements and ensure all procurement documentation is retained.

Finding Text

Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. During our testing, we noted the following exceptions: • SCH The Organization’s procurement policy did not meet the requirements defined by 2 CFR 200. • The Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.). Effect The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors. Questioned Costs None identified. Cause The Organization lacks a uniform Procurement, Suspension & Debarment policy that is in compliance with the Federal regulations and/or the terms and conditions of the Federal award. Recommendation • We recommend the Organization review and update its procurement policy to ensure the policy meets the 2 CFR Part 200 Procurement requirements. • We recommend the Organization retain all documentation and support to show that the procurement policy was followed. Views of Responsible Officials The Organization will be reviewing and updating our procurement policy for any missing items not currently noted in our policies or procedures. Gateway and RC Telecom are our sole-source vendors based on the scope and nature of the work and our unique phone system set up. However, no documentation was recorded or kept for this vendor, besides quotes prior to purchases as well as purchase orders per our current purchasing procedure. Our current policy does mention competitive bidding, and the procedure mentions sole-source documentation and what we use for this documentation (currently a bid or quotation), but we need to expand and not just reference the CFR, but at minimum list our thresholds for procurement methods and other required elements. When we meet the bidding threshold, sealed bids are kept in our files. We have not had any sealed bid purchases in fiscal year 2023.

Corrective Action Plan

Recommendation: Our auditors had the following recommendations: 1. Our auditors recommended the Organization review and update its procurement policy to ensure the policy meets the 2 CFR Part 200 Procurement requirements. 2. Our auditors recommend the Organization retain all documentation and support to show that the procurement policy was followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will be reviewing and updating our procurement policy for any missing items not currently noted in our policies or procedures. Gateway and RC Telecom are our sole-source vendors based on the scope and nature of the work and our unique phone system set up. Our current policy does mention competitive bidding, and the procedure mentions sole-source documentation and what we use for this documentation (currently a bid or quotation) but we need to expand and not just reference the CFR, but at minimum list our thresholds for procurement methods and other required elements. When we mee the bidding threshold, sealed bids are kept in our files. We have not had any sealed bid purchases in fiscal year 2023.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 234 2023-001
    Significant Deficiency
  • 236 2023-003
    Significant Deficiency
  • 237 2023-001
    Significant Deficiency
  • 238 2023-002
    Significant Deficiency
  • 239 2023-003
    Significant Deficiency
  • 240 2023-001
    Significant Deficiency
  • 241 2023-002
    Significant Deficiency
  • 242 2023-003
    Significant Deficiency
  • 243 2023-001
    Significant Deficiency
  • 244 2023-002
    Significant Deficiency
  • 245 2023-003
    Significant Deficiency
  • 576676 2023-001
    Significant Deficiency
  • 576677 2023-002
    Significant Deficiency
  • 576678 2023-003
    Significant Deficiency
  • 576679 2023-001
    Significant Deficiency
  • 576680 2023-002
    Significant Deficiency
  • 576681 2023-003
    Significant Deficiency
  • 576682 2023-001
    Significant Deficiency
  • 576683 2023-002
    Significant Deficiency
  • 576684 2023-003
    Significant Deficiency
  • 576685 2023-001
    Significant Deficiency
  • 576686 2023-002
    Significant Deficiency
  • 576687 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Center, Affordable Care Act for New and Expanded Services $5.05M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children (wic) $4.29M
93.224 Covid-19: American Rescue Plan Act Funding for Health Centers $3.50M
93.498 Covid-19: Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $644,424
93.527 Covid-19: Fy 2023 Expanding Covid-19 Vaccination $412,177
93.566 Refugee and Entrant Assistance - State Administered Programs $44,864
21.027 Covid-19: Coronavirus State and Local Fiscal Recovery Funds $28,980
14.218 Community Development Block Grants/entitlement Grants $14,154
10.561 Supplemental Nutrition Assistance Program (snap) $7,963
93.527 Consolidated Health Center, Affordable Care Act for New and Expanded Services $0