Finding 37205 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: Multiple procurements lacked necessary documentation, including approvals and bidding evidence.
  • Impacted Requirements: Compliance with procurement standards and suspension/debarment checks was not met for several transactions.
  • Recommended Follow-Up: Ensure all procurement documentation is complete and verify compliance with approval and bidding processes moving forward.

Finding Text

During our testing, we noted the following matters related to procurement and suspension and debarment. Assistance Listing Number 93.129 ? For 1 of 5 procurements, the Association provided us with the contract subsequent to the fiscal year rather than the contract in effect during the fiscal year. As such, we were not able to test for approval of the procurement. ? For 2 of 5 procurements, no evidence of approval of the procurement provided to us. ? For 4 of 5 procurements, no evidence of three bids under the Association's standard purchasing provided to us. ? For 1 of 5 procurements, the history of procurement was not provided to us. ? For 2 of 2 procurements, evidence of the suspension and debarment check before entering into the covered transaction and evidence of the review and approval of the verification check not provided to us. Assistance Listing Number 93.527 ? For 2 of 5 procurements, no evidence of approval of the procurement provided to us. ? For 3 of 5 procurements, no evidence of three bids under the Association's standard purchasing provided to us. ? For 1 of 5 procurements, the history of procurement was not provided to us. ? For 1 of 5 procurements, the Association did not document its sole source justification as part of the history of procurement. The justification was drafted and provided to us as part of our inquiries. ? For 1 of 1 procurements, evidence of the suspension and debarment check before entering into the covered transaction and evidence of the review and approval of the verification check not provided to us.

Corrective Action Plan

Technical and Non-Financial Assistance to Health Centers ? Assistance Listing No. 93.129 and 93.527 Recommendation: Design controls to ensure compliance with federal procurement regulation and federal procurement policy, including debarment. Explanation of disagreement with audit finding: For the audit period 7/1/2021 ? 6/30/2022, the NMPCA had a service with Compliatric to check for suspension or debarment against the OIG database. This test was performed monthly, and confirmations were received and stored. The NMPCA procurement policy provides for three sets of purchasing requirements, as indicated in federal regulations by standard procurement requirements, purchasing requirements under the Simplified Acquisition Threshold and purchasing requirements under the Micro Purchase Threshold. The auditors did not identify to NMPCA management any purchases in excess of the Simplified Acquisition Threshold. For purchases under the Simplified Acquisition Threshold, the NMPCA purchasing policy does not require a minimum number of bids, nor does it require a vendor contract. The only requirement under the policy for purchases under the Simplified Acquisition Threshold and above the Micro Purchase Threshold is two signatures, which are supplied with the check. Action taken in response to finding: No action needed. Name(s) of the contact person(s) responsible for corrective action: John Dailey Planned completion date for corrective action plan: 6/30/2023

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 37206 2022-002
    Significant Deficiency
  • 37207 2022-003
    Significant Deficiency
  • 37208 2022-004
    Significant Deficiency
  • 37209 2022-001
    Significant Deficiency
  • 37210 2022-002
    Significant Deficiency
  • 37211 2022-001
    Significant Deficiency
  • 37212 2022-002
    Significant Deficiency
  • 37213 2022-003
    Significant Deficiency
  • 37214 2022-004
    Significant Deficiency
  • 613647 2022-001
    Significant Deficiency
  • 613648 2022-002
    Significant Deficiency
  • 613649 2022-003
    Significant Deficiency
  • 613650 2022-004
    Significant Deficiency
  • 613651 2022-001
    Significant Deficiency
  • 613652 2022-002
    Significant Deficiency
  • 613653 2022-001
    Significant Deficiency
  • 613654 2022-002
    Significant Deficiency
  • 613655 2022-003
    Significant Deficiency
  • 613656 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.129 Technical and Non-Financial Assistance to Health Centers $1.17M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $770,605
93.778 Medical Assistance Program $732,032
93.129 Covid-19 - Technical and Non-Financial Assistance to Health Centers $150,852
93.788 Opioid Str $130,000
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $60,000
93.527 Covid-19 - Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $45,654
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $6,100