Finding 49856 (2022-001)

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Requirement
I
Questioned Costs
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Year
2022
Accepted
2023-09-27

AI Summary

  • Core Issue: The System failed to meet competitive bidding requirements for HEERF funding, specifically for the School of Nursing project.
  • Impacted Requirements: Non-compliance with procurement procedures under the Uniform Guidance, leading to insufficient documentation of transactions.
  • Recommended Follow-Up: Establish and document formal procurement policies to ensure compliance and maintain adequate records for future transactions.

Finding Text

Finding 2022?001 ? Assistance Listing No. 84.425 ? COVID-19 Education Stabilization Fund Criteria The System is required to use procurement procedures for the acquisition of property or services under COVID-19 Education Stabilization Fund, HEERF funding in compliance with the competitive procurement requirements of the Uniform Guidance. The System must maintain records sufficient to detail procurement transactions for the acquisition of property or services, and documentation showing compliance with procurement requirements under the Uniform Guidance. Condition/Context As part of our compliance testing, we reviewed the HEERF institutional funds expended on acquisition of property or services. As a result of this review, we noted that competitive bidding procurement requirements for HEERF awards were not met and competitive bids were not obtained for the School of Nursing project funded by HEERF. Cause The System did not establish a formal documented procurement policy to ensure compliance with applicable requirements under HEERF awards and competitive bids were not obtained. While the System worked collaboratively with the general contractor in the selection of subcontractors for the capital projects, competitive proposals were not obtained for the general contractor in accordance with the requirements of the Uniform Guidance procedure standards. While the System did review and select subcontractors with input from the general contractor, the Systems process for bidding relative to the subcontractors, including the final review and engagement of the subcontractors was not documented. Effect Documentation was not sufficient to demonstrate compliance with applicable procurement standards. Recommendation We recommend that the System establish procurement policies to meet federal compliance requirements. Views of Responsible Officials Management agrees with the recommendation and will establish and document written procurement procedures and maintain sufficient documentation for transactions including acquisition of property or services to ensure competitive bidding is obtained.

Corrective Action Plan

CORRECTIVE ACTION PLAN U.S. Department of Health & Human Services: Finger Lakes Regional Health System, Inc. (the System) respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully?s Trail Pittsford, New York 14534 Audit period: January 1, 2022 ? December 31, 2022 The findings from the 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? MAJOR FEDERAL AWARD PROGRAM SIGNIFICANT DEFICIENCY 2022-001 Assistance Listing No. 84.425 ?COVID-19 Education Stabilization Fund Recommendation: Our auditors noted that competitive bidding procurement requirements for HEERF awards were not met and competitive bids were not obtained for the School of Nursing project funded by HEERF. While the System worked collaboratively with the general contractor in the selection of subcontractors for the capital projects, competitive proposals were not obtained for the general contractor in accordance with the requirements of the Uniform Guidance procedure standards. While the System did review and select subcontractors with input from the general contractor, the System?s process for bidding relative to the subcontractors, including the final review and engagement of the subcontractors was not documented. Our auditors recommended that the System establish a formal documented procurement policy to meet federal compliance requirements. Action Taken: Management has established a grant funding committee that is establishing written procurement procedures and documentation requirements for transactions including acquisition of property or services to ensure competitive bidding is obtained when required by federal funders. Trisha Koczent, CFO is responsible for implementing this plan and can be reached at (315) 787-4000.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $6.90M
84.268 Federal Direct Student Loans $690,338
84.425 Education Stabilization Fund $628,290
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $426,207
93.155 Rural Health Research Centers $258,376
84.063 Federal Pell Grant Program $178,751
93.301 Small Rural Hospital Improvement Grant Program $100,516
84.007 Federal Supplemental Educational Opportunity Grants $7,500