Finding Text
United States Department of Health and Human Services Pass-through from North Carolina Department of Health and Human Services Program Name: Block Grants for Prevention and Treatment of Substance Abuse Federal Assistance Listing Number - 93.959 Finding 2022-004 Significant Deficiency and Noncompliance - Procurement Criteria: All grantees that expend federal funds must comply with the procurement guidelines found in 2 CFR 200.318- .327 and use documented procurement procedures that are consistent with the applicable laws and regulations for the acquisition of property or services required under a Federal award or subaward. Condition and Context: The Organization has developed a basic purchasing policy that includes appropriate control activities; however, the policy does not include complete procurement procedures that fully align with the requirements of section 2 CFR 200.318-.327. The Organization's program expenditures for the year ended June 30, 2022 did not include purchases in excess of the Simplified Acquisition Threshold and thus informal procurement procedures were acceptable. Cause: As the Organization has only recently started receiving federal awards, they were not aware of these requirements and did not have the necesssary policies and procedures in place to comply with the procurement guidelines. Effect: Without a documented procurement policy that aligns with the requirements of 2 CFR 200.318-.327, purchases may be made under the federal program that do not comply with the relevant procurement standards established by 2 CFR 200. Recommendation: Management should formulate and adopt a procurement policy that includes the required elements of 2 CFR 200.318-.327. Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in the corrective action plan. See Corrective Action Plan.