Finding 374622 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-08

AI Summary

  • Core Issue: The health center's procurement policy sets a small purchase threshold at $25,000, which is above the federal limit of $10,000.
  • Impacted Requirements: The organization failed to document vendor checks against federal suspension or debarment lists, violating 45 CFR 75.329.
  • Recommended Follow-Up: Revise the procurement policy to align with federal guidelines and conduct annual reviews for compliance.

Finding Text

Health Center Program Cluster Federal Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award Nos. 6 H80CS24171-12-01, 3 H8FCS40636-01-01, and 4 H8GCS48070-01-01 Program Year 2023 Criteria or Specific Requirement – Procurement, Suspension, & Debarment – 45 CFR 75.329 Condition – The Organization’s procurement policy established a threshold of $25,000 for small purchase procedures rather than the $10,000 prescribed by US DHHS. In addition, the health center did not maintain documentation demonstrating the activities performed to demonstrate a vendor is not included on a federal suspension or debarment list. Questioned Costs – Unknown Context – A sample of sixteen procurements were tested out of a population of one hundred fifty-six transactions subject to procurement requirements. The population sampled represented $136,774 in federal expenditures. The sample was not, and is not intended to be, statistically valid. Of the sixteen procurements tested, four procurements in the amount of $56,451 were not completed in accordance with federal procurement requirements. Effect – Purchases were made without fully adhering to federal procurement requirements. Cause – The Organization’s procurement policy included a small purchases threshold that exceeds US DHHS guidance. Identification as a Repeat Finding – Not a repeat finding Recommendation – The Organization should revise its procurement policy to reflect the appropriate small purchase threshold and the policy should be reviewed annually to ensure compliance with the federal regulations.

Corrective Action Plan

Promise Community Health Center established the threshold of $25,000 for small purchase procedures rather than the $10,000 noted by US DHHS. Promise also reviewed its procurement samples tested and noted that many of the samples were individually below the threshold of $10,000 and misunderstood this to be a full purchase order of $10,000 to require a secondary quote. Promise will revise its procurement policy to reflect the appropriate small purchase threshold and the policy will continue to be reviewed bi‐annually and approved by the board. Kara Acevedo, Chief Financial Officer, is responsible for the oversight of the corrective action. Completion of the corrective action plan is expected by March 31, 2024.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 374623 2023-001
    Significant Deficiency
  • 374624 2023-001
    Significant Deficiency
  • 374625 2023-001
    Significant Deficiency
  • 951064 2023-001
    Significant Deficiency
  • 951065 2023-001
    Significant Deficiency
  • 951066 2023-001
    Significant Deficiency
  • 951067 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $518,706
93.498 Provider Relief Fund $147,971
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $101,608
93.800 Organized Approaches to Increase Colorectal Cancer Screening $26,978
93.110 Maternal and Child Health Federal Consolidated Programs $25,625
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $20,000
93.461 Covid-19 Testing for the Uninsured $-5,896