Finding Text
2020-105 Lack of Required Policies Associated with Procurement (initially reported 2020)
Assistance Listing Number: 93.224
Name of Federal Agency: Department of Health and Human Services, HRSA
Program Title: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care)
Compliance Requirement: Procurement, Suspension and Debarment
Pass-through Entity: N/A
Federal Grant/Contract Number and Grant Year: 6H80CS06452-15 (2020), COVID-19 1H8CCS35035-01 (2020), COVID-19 1H8DCS36007-01 (2020) and COVID-19 1H8ECS39010-01 (2020)
Finding Type: Significant Deficiency in Internal Control
Known Questioned Costs: $0
Condition: The Organization does not have written policies in regards to procurement to ensure federal awards are being spent in accordance with federal and other specific requirements under the award.
Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Also, based on grant compliance requirements related to procurement and suspension and debarment, procurements under federal awards are to be made in compliance with applicable federal regulations and other procurement requirements specific to an award of sub award. In addition, ensure that covered transactions should be only with entities that are not suspended, debarred, or otherwise excluded.
Cause: The Organization has not documented procedures which reflect applicable state and local laws and regulations to conform to the applicable federal statutes and procurement requirements identified in 2 CFR part 200.
Effect: The Organization could obtain goods and services outside of the procurement requirements identified in 2 CFR part 200.
Recommendation: The Organization should create written policies for procurement to ensure federal awards are being spent in accordance with federal and other requirements under the award.
Views of Responsible Officials and Planned Corrective Actions: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization will review and update its existing policies to include procurement to ensure federal awards are being spent in accordance with federal and other specific requirements under the awards. The Organization expects to have this implemented by March 1, 2023.