Finding 398619 (2023-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-05-29

AI Summary

  • Core Issue: The organization lacks a written procurement policy required by federal regulations.
  • Impacted Requirements: Noncompliance with Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations.
  • Recommended Follow-Up: Develop and implement a compliant procurement policy by 2024.

Finding Text

Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.847, 93.867, & 93.103 Federal Award Identification Number and Year: Various Award Period: January 1, 2023, through December 31, 2023 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires organizations to have a written procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. Condition: During our testing, it was noted that the Organization does not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations. Questioned costs: None Context: The new policy was being developed during 2023 Cause: The new policy was not put in place until 2024 Effect: Noncompliance with federal procurement requirements Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Views of responsible officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.

Corrective Action Plan

Procurement Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Organization has a procurement policy in place, it is noncompliant with the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. The Organization has experienced substantial growth in recent years and in support of this expansion, hired an experienced CFO in early 2022. The new CFO identified the need for a compliant procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. To facilitate the adherence to the new procurement policy, the Organization purchased new ERP software and both contracted with an outside organization and hired new internal staff to oversee the implementation of this software during 2023. The implementation of this software was completed at the end of 2023 and placed into service January 2024. The new procurement policy was reviewed by the auditors during the 2022 audit and a determination was made that had the new policy been in effect and followed, the Organization’s practices would have met the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. With the new software now in place, this policy will become effective during 2024. A staff member had been selected and fully trained to oversee the procurement function, but then retired at the end of 2023. A new staff member is currently being hired and will be specifically trained on the federal procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Erica Vogt, CFO Planned completion date for corrective action plan: January 1, 2024

Categories

Procurement, Suspension & Debarment Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 398620 2023-001
    Material Weakness Repeat
  • 398621 2023-001
    Material Weakness Repeat
  • 398622 2023-001
    Material Weakness Repeat
  • 398623 2023-001
    Material Weakness Repeat
  • 398624 2023-001
    Material Weakness Repeat
  • 398625 2023-001
    Material Weakness Repeat
  • 398626 2023-001
    Material Weakness Repeat
  • 398627 2023-001
    Material Weakness Repeat
  • 975061 2023-001
    Material Weakness Repeat
  • 975062 2023-001
    Material Weakness Repeat
  • 975063 2023-001
    Material Weakness Repeat
  • 975064 2023-001
    Material Weakness Repeat
  • 975065 2023-001
    Material Weakness Repeat
  • 975066 2023-001
    Material Weakness Repeat
  • 975067 2023-001
    Material Weakness Repeat
  • 975068 2023-001
    Material Weakness Repeat
  • 975069 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $1.18M
93.867 Vision Research $128,694
93.103 Food and Drug Administration_research $41,537