Finding 49984 (2022-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-09-24

AI Summary

  • Core Issue: The Health Center lacks properly documented procurement and conflict of interest policies that meet federal requirements.
  • Impacted Requirements: Non-compliance with CFR 200.320 and 200.318 regarding procurement procedures and conflict of interest policies.
  • Recommended Follow-Up: Update procurement and conflict of interest policies to align with Uniform Guidance and ensure proper documentation for all transactions.

Finding Text

2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations (CFR) section 200.320 states the non-Federal entity must have and use documented procurement procedures following specific requirements for different methods of procurement depending on size and type of purchase. Thresholds for these categories (micro-purchase, simplified acquisition threshold) refer to using the Federal Acquisition Regulations (FAR), unless a different threshold has been specifically approved. Specifically, under FAR multiple quotes are generally required for purchases over the micro-purchase threshold, or documentation should be maintained explaining why multiple quotes were not obtained. CFR 200.318 also states specific requirements for conflict of interest policies and procedures non-federal entities must maintain, including specifically addressing conflicts related to contracts supported by federal awards. Condition: During our testing, we noted the Health Center did not have properly documented procurement policy that met the federal requirements. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. We also noted the Health Center's conflict of interest policy did not meet all the requirements under Uniform Guidance. Questioned costs: None Context: During our testing, it was noted that the Health Center had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all of the necessary elements, as required by federal regulations. Based on our testing, the Health Center followed the policy in place, but the micro purchase threshold requiring multiple quotes or documentation of sole source procurement under the policy is set at $50,000, where the requirement is $10,000 unless specific steps have been taken to certify a higher threshold. Similarly, the Health Center has a conflict of interest policy and procedures in place, but the language does not meet the specific requirements of Uniform Guidance. Noted both policies to be updated to be in compliance with Uniform Guidance compliance near year-end in response to the prior year audit finding, but due to the timing policies in place for majority of year were not in compliance. Cause: The Health Center had not yet updated their procurement and conflict of interest policies to meet Uniform Guidance requirements. Effect: Without updates to procurement and conflict of interest policies over these compliance requirements the Health Center is not fully compliant with Uniform Guidance requirements. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number 2021-002 was a significant deficiency. Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Views of responsible officials: There is no disagreement with the audit finding. Policies were updated near the end of 2022 to be in compliance with requirements.

Corrective Action Plan

U.S. Department of Health and Human Services 2022-002 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement and Conflict of Interest Policies were recently revised in Oct 2022 and Dec 2022 ahead of HRSA operational site visit to meet Uniform Guidance requirements. Staff have been trained on requirements related to the procurement thresholds and documentation standards. Documentation and discussion of procurement standards will be captured per that policy, with board action and discussion. Name(s) of the contact person(s) responsible for corrective action: Lori Zook, CFO Planned completion date for corrective action plan: 12/20/2022

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 49985 2022-003
    Significant Deficiency Repeat
  • 49986 2022-002
    Significant Deficiency Repeat
  • 49987 2022-003
    Significant Deficiency Repeat
  • 49988 2022-002
    Significant Deficiency Repeat
  • 49989 2022-003
    Significant Deficiency Repeat
  • 626426 2022-002
    Significant Deficiency Repeat
  • 626427 2022-003
    Significant Deficiency Repeat
  • 626428 2022-002
    Significant Deficiency Repeat
  • 626429 2022-003
    Significant Deficiency Repeat
  • 626430 2022-002
    Significant Deficiency Repeat
  • 626431 2022-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.76M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $1.58M
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $668,916
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $19,915