Finding Text
Finding 2022-002 U.S. Department of Health and Human Services 93.421 ? Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation?s Health Procurement (Significant Deficiency) Criteria: In accordance with Title 2 CFR Part 200.318, the Organization must maintain records to document the history of procurement of a contractor. Records include, but are not limited to, rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: For 2 procurements made during fiscal year 2022, the competitive bid documentation did not include evidence of review or approval by a department/market supervisor or the procurement team. Further, such documentation was not maintained with the signed contractor agreement. Cause: Documentation supporting the procurement of contractors was not maintained in a logical manner to document the history of procurement. Effect: Without appropriate documentation, the Organization may be unable to support whether the procurement of the contractors was performed in accordance with the procurement standards noted in Title 2 CFR Part 200.318. Recommendation: Management should develop an approval policy for competitive bids documentation as well as a records retention policy for procurement decisions made that includes the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Vendor files should be stored in a centralized location within the Organization. Management should also perform a periodic review of contractor files to ensure such documentation is maintained. Views of Responsible Officials: Although sole source and competitive bid information were obtained, they were not located in a centralized location and the written supporting approvals were not maintained. By the end of October 2023, Management will update, enforce, and retrain team members on procurement policies to include competitive bid documentation and record retention requirements. The required supporting documentation will also be housed in a centralized location and Management will perform periodic reviews to ensure it is properly maintained. To further expand training, by the end of October 2023, all key finance and program personnel will also complete Federal Grants Management training offered by the CDC Foundation.