Finding Text
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.