Finding Text
Type of Finding: Material Weakness in Internal Control over Compliance
Federal Agency: United States Department of Health and Human Services
Federal Program Name: Family Violence Prevention and Services/Discretionary
Assistance Listing Number: 93.592
Federal Award Identification Number and Year: 90EV0467
Award Period for 90EV0467-02 and 90EV0467-03: September 30, 2020 through September 29, 2024
Award Period for 90EV0467-C6: March 15, 2021 through September 30, 2025
Criteria or specific requirement: CFR 200.318 states the non-Federal entity's documented
procurement procedures must conform to the procurement standards identified in CFR sections
200.317 through 200.327.
Condition: During our procurement testing, it was noted the procurement policy was written to comply
with OMB Circular A-110 (2 CFR 215). As the requirements stated in the Circular have been
superseded by OMB Uniform Guidance 2 CFR part 200, the policy as it is written is out of compliance.
Questioned costs: None.
Context: Though the current procurement policy was not updated to comply with 2 CFR Part 200
procurement standards the 3 samples selected during our audit did not identify instances of noncompliance
with procurement standards.
Cause: Management was not aware of the specific compliance requirement changes and thus, did not
update its procurement policy.
Effect: By not having an updated policy, the Organization could enter into a material transaction that is
not compliant with 2 CFR Part 200.
Repeat Finding: No.
Recommendation: We recommend the client update its procurement policy so it is compliant with 2
CFR Part 200.
Views of responsible officials: Management agrees with the finding and has provided its corrective
action plan.