Finding 381193 (2023-006)

U.S. Department of Health and Human Services Federal Financial Assistance Listing Number 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services ‐ 6H79SM083306‐01M002 Procurement and Suspension and Debarment Significant Deficiency in Internal Control over Compliance Criteria: The Uniform Guidance, Section 200.303 Internal Controls, requires the non‐federal entity must establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. The non‐Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non‐ Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.318 through 200.327. Condition: The Organization did not have a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations. Cause: There is a lack of controls over the written procurement, suspension and debarment policy. Effect: Failure to maintain a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations may result in disallowed costs. Questioned Costs: None. Context/Sampling: EB reviewed the procurement, suspension and debarment policy. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that management implement a written procurement, suspension and debarment policy that meets Federal, State, local, and tribal laws and regulations. We also recommend that management review this policy regularly to confirm that it meets the requirements. Views of Responsible Individuals: Management agrees with the finding.