FAC Explorer

Finding 44080 (2022-002)

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Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-06-29
Audit: 50495
Organization: Integral Global Health, Inc. (GA)
Auditor: Grace CPAS LLC

AI Summary

  • Core Issue: The Organization's procurement policy does not comply with Uniform Guidance Procurement Standards.
  • Impacted Requirements: Federal funding mandates adherence to regulations regarding vendor review and procurement policies.
  • Recommended Follow-Up: Update procurement policies and verify vendor status in the SAM Exclusion system before contracting.

Finding Text

Finding 2022-002 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Procurement and Suspension and Debarment Condition: During our testing of procurement, suspension, and debarment, we noted that the Organization?s procurement policy was not in compliance with Uniform Guidance Procurement Standards. Our testing also revealed no documentation was provided to verify that the vendor was reviewed within the SAM Exclusion system prior to contracting. Criteria: Since the Organization receives federal funding, it must update its procurement policy to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart D ? 200.317-32. Additionally, it must review vendor debarment or suspension status prior to contracting to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart C ? 200.214 and 2 CFR Part 180. Cause: Oversight of updating the Organization?s established procurement policies and procedures, and oversight in reviewing vendor suspension and debarment status within the SAM Exclusion website. Effect: Failure to update the Corporation?s policies and procedures may result in procurement and purchases not meeting compliance requirements, and failure to review vendor suspension and debarment status within the SAM Exclusion website may result in payments to ineligible vendors. Accordingly, the Organization will not being in compliance with the requirements per Uniform Guidance Procurement Standards. Questioned Costs: None noted. Recommendation: We recommend that the Organization review and update its established policies, procedures and controls to ensure the procurement policy is in alignment with Uniform Guidance Procurement Standards, and we also recommend that the Organization verify vendor status within the SAM Exclusion website for debarment or suspension status. Management?s Response: See Corrective Action Plan

Corrective Action Plan

Finding 2022-002: Procurement and Suspension and Debarment - Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have developed a comprehensive corrective action plan to address the noncompliance and strengthen our procurement and suspension/debarment processes: Procurement Policy Update: We have initiated a review and update of our procurement policy to ensure alignment with the Uniform Guidance Procurement Standards. This updated policy will incorporate the necessary provisions and requirements outlined in government regulations. Vendor Review Process: We have implemented a formal process to review vendor suspension and debarment status within the SAM Exclusion system prior to contracting. This process will be integrated into our procurement procedures to ensure compliance with the Uniform Guidance Procurement Standards. Training and Awareness: We will provide training sessions to staff involved in procurement processes, emphasizing the importance of adhering to the updated procurement policy and conducting thorough vendor reviews within the SAM Exclusion system. This training will enhance their understanding of the regulatory requirements and their roles in compliance. Documentation and Record-Keeping: We have established procedures for documenting and retaining records of vendor reviews within the SAM Exclusion system. This documentation will serve as evidence of our due diligence and compliance with the Uniform Guidance Procurement Standards. Monitoring and Internal Controls: We will strengthen our monitoring procedures and internal controls to ensure ongoing compliance with procurement and suspension/debarment requirements. Regular reviews will be conducted to verify adherence to the updated procurement policy and vendor review processes. Continuous Improvement: We are committed to continuous improvement in our procurement and suspension/debarment processes. We will establish a mechanism for periodic reviews of our policies, procedures, and controls to identify areas for enhancement and ensure they remain effective and aligned with the Uniform Guidance Procurement Standards. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $725,632