Finding Text
Substance Abuse and Mental Health Services ? Projects of Regional and National Significance, Assistance Listing Number 93.243, U.S. Department of Health and Human Services, Award Number 1H79TI084470-01, Award Year 2022 Criteria or Specific Requirement ? Procurement, Suspension, and Debarment ? 2 CFR ? 200.317?.327; 2 CFR ? 200.214 Condition ? Red Rock is required to have and use documented procurement procedures, consistent with federal, state, and local laws and regulations, for the acquisition of property or services required under a federal award or subaward and determine an entity is not suspended or debarred before awarding a contract. Questioned Costs ? None Context ? Two purchases exceeded the small purchase threshold for this program during 2022. Neither had documentation supporting price or rate quotations and neither had documentation that procedures were performed to ensure vendors were not debarred, suspended, or otherwise excluded from participation in federal assistance programs or activities. Effect ? Red Rock?s procurements were not conducted in accordance with federal laws and regulations and Red Rock?s procurement policy does not meet federal requirements. In addition, the entity did not have a policy to check suspension and debarment for contracts using federal awards. Cause ? Red Rock?s procurement procedures are not tailored to include consideration of the Uniform Guidance, including methods of procurement to be followed, the thresholds at which certain procedures are necessary, provisions regarding conflicts of interest, and procedures to ensure vendors are not debarred or suspended from participation in federal assistance programs or activities. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? Red Rock should revise its procurement policy to ensure procurements are conducted in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding, and changes to Red Rock?s procurement policy are being implemented during FY 2023. Purchasing staff will be trained on federal procurement requirements and will be provided a copy of the new policy.