Finding 498544 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-26

AI Summary

  • Core Issue: The Institute failed to provide necessary procurement documentation and did not verify that vendors were not suspended or debarred from federal contracts.
  • Impacted Requirements: Noncompliance with 2 CFR 200.514 and 200.318 regarding internal controls and procurement standards.
  • Recommended Follow-Up: Ensure proper documentation of procurement processes and verify vendor eligibility annually before contract awards.

Finding Text

Department of Health and Human Services Federal Assistance Listing No. 93.185 Community-Based Workforce to Build COVID-19 Vaccine Confidence and Health Resources and Service Administration. Federal Assistance Listing No. 93.011 CDC Communities RISE Noncompliance and significant deficiency over Procurement and Suspension and Debarment Repeat Finding: No Condition: During our audit we noted that procurement documentation was not available to support the selection of the vendors. Also, we were unable to obtain documentation to support the Institute entered into contractual agreements with vendors who were not suspended or debarred from doing business with the Federal government. Criteria: In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides guidance on internal controls over Federal programs based upon the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO requires entities to establish and maintain effective internal controls to achieve operational, reporting and compliance objectives. Per 2 CFR 200.320 General procurement stands: (a) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold. (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Finding 2023-01 (continued) Per 2 CFR 200.318 General procurement stands: (b) The Non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Per Uniform Guidance, Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Cause: The Institute did not apply the required procurement policy relative to sole source contracts in accordance with Uniform Guidance. Management also did not complete a review of vendors/contractors to verify they are not suspended, debarred, or otherwise excluded before contracting. Effect: The Institute does not maintain adequate documentation on whether they have entered into transactions with eligible entities and is in compliance with Federal procurement guidelines. Questioned Costs: Unknown Recommendation: We recommend the Institute maintain adequate documentation to support the procurement process followed when awarding the Federal contract. We also recommend the Institute follow their process to verify that entities are not suspended, debarred, or otherwise excluded annually at time of award and to document these procedures. Views of Responsible Officials: See schedule of corrective action plan.

Corrective Action Plan

Finding 2023-001: Significant deficiency over Procurement and Suspension and Debarment Responsible Official’s Response and Corrective Action Plan We concur with the finding. Due to the transition in the accounting department, we were not aware of these specific criteria at the time. We were notified of these requirements after the end of fiscal year 2023. To address this issue, WE in the World implemented a procurement policy as of March 2024. We will continue to use this comprehensive process during fiscal year 2024 and beyond to ensure proper documentation and compliance with procurement regulations. This process will include: 1. Ensuring that all sole source vendor selections are properly documented and justified. 2. Verifying and maintaining records that confirm vendors are not debarred or suspended from doing business with the Federal Government before entering into contractual agreements. We are committed to improving our procedures and ensuring compliance with all applicable regulations moving forward. Planned Implementation Date of Corrective Action Plan Instituted March 2024 Person Responsible for Corrective Action Plan Marta Bustos Kuperwasser Finance Director

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 498545 2023-001
    Significant Deficiency
  • 498546 2023-001
    Significant Deficiency
  • 498547 2023-001
    Significant Deficiency
  • 498548 2023-001
    Significant Deficiency
  • 498549 2023-001
    Significant Deficiency
  • 498550 2023-001
    Significant Deficiency
  • 1074986 2023-001
    Significant Deficiency
  • 1074987 2023-001
    Significant Deficiency
  • 1074988 2023-001
    Significant Deficiency
  • 1074989 2023-001
    Significant Deficiency
  • 1074990 2023-001
    Significant Deficiency
  • 1074991 2023-001
    Significant Deficiency
  • 1074992 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.268 Immunization Cooperative Agreements $712,658
93.011 Health Resources and Service Adminstration (hrsa 2) $171,532
93.435 Rhode Island Phase II Amend 3 $122,355
93.011 Commuity-Based Workforce to Build Covid-19 Vaccine Confidence $95,535
93.185 Cdc Communities Rise $23,966