Finding Text
2022-001 – Procurement and Suspension and Debarment
Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance
Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network
Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all
grant numbers.
Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318
through 200.326. They must use their 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.
Condition: The Organization's procurement policies were not complete and the Organization did not follow
the federal procurement standards which provides specific guidance including process and documentation
requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326.
Cause: The Organization’s procurement policies do not include the federal procurement requirements
noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the
required procurement documentation, provide for full and open competition, or provide support for limitation
of such competition.
Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects
funded by federal sources. The Organization may have to pay back funds received for a project where
federal funds were used for the procurement of products or services, but the required federal process was
not met.
Questioned Costs: No costs were questioned as a result of this finding.
Recommendation: The Organization should update their procurement policy to include all requirements as
noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required
processes.
View of Responsible Officials: Management agrees with the finding and plans to update their procurement
policy.