Finding Text
Department of Health and Human Services Federal Assistance Listing #93.697 COVID-19 Testing and Mitigation for Rural Health Clinics Procurement and Suspension and Debarment Material Weakness in Internal Control Over Compliance and Noncompliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non-Federal entity must use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal law and standards. Condition: Written procurement policies were not updated to conform to applicable standards under Uniform Guidance. In addition, the Medical Center did not obtain quotes from multiple vendors on purchases over the micro purchase threshold. Cause: The Medical Center did not have proper procedures to ensure its written procurement policies were updated to conform to the requirements identified in Uniform Guidance and to ensure quotes were obtained for all purchases over the micro purchase threshold. Effect: Without an effective policy internal control process in place, a vendor purchase over the micro purchase threshold was made without seeking other quotes first. Questioned Costs: None noted. Context: No sampling was performed as the procurement policy was examined in its entirety and all vendor purchases over the micro purchase threshold were tested. Repeat Finding from Prior Years: No Recommendation: We recommend the Medical Center ensure its written procurement policies are updated to conform to the requirements identified in Uniform Guidance. We also recommend the Medical Center implement a control process which includes ensuring quotes are obtained for all purchases over the micro purchase threshold. Views of Responsible Officials: Management agrees with the finding.