Finding 388315 (2023-002)

Finding 2023-002 Program Name: WIC Special Supplemental Nutrition Program for Women,Infants, and Children and Grants for Capital Development in Health Centers Federal Assistance Listing Number: 10.557 and 93.526 Federal Agencies: United States Department of Agriculture (USDA) and and U.S. Department of Health and Human Services Finding Type: Material Weakness Compliance Requirement: Procurement Condition: Ampla Health did not have adequate procurement policies in place that meet the minimum federal requirements for procurement standards. We examined the procurement records for nine vendors where Ampla Health expended federal funds. For all four sole source procurement records reviewed, Ampla Health did not retain documentation of the sole source determination or have an approved sole source vendor list. For two of three vendors selected in the small acquisition threshold, Ampla Health could not provide competing quotes or sufficient evidence to demonstrate procurement was performed. For one of three vendors selected in the small acquisition threshold, Ampla Health was only able to provide procurement support for a portion of the funds expended. Criteria: Under 2 CFR sections 200.318 through 200.326 and 45 CFR 75.327 Ampla Health is required to implement certain written procurement policies and procedures that adhere to the minimum Federal Procurement standards. Ampla Health must use its own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200 and maintain sufficient records to detail the history of procurements. Cause: Ampla Health did not have a policy in place that meets the minimum federal requirements under Uniform Guidance. In addition, Ampla Health could not provide support to demonstrate that it performed the necessary procurement steps or retained documentation demonstrating compliance with Uniform Guidance for purchases made with federal funds. Effect: Ampla Health was not in compliance with federal regulations or their own policies. Recommendation: Ampla Health should update their procurement policy to meet the minimum federal requirements and ensure procurement policies are being followed for all procurement levels with written documentation. Additionally, management should ensure individuals participating in the procurement process receive adequate training and guidance on procurement rules under the Uniform Guidance. View of Responsible Officials: Management will review the procurement policy and make necessary changes to ensure the policy meets all federal requirements.