Finding 516674 (2024-005)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2024-12-23

AI Summary

  • Core Issue: The Organization's procurement policy does not meet federal and state requirements, specifically failing to include necessary procurement methods outlined in Uniform Guidance.
  • Impacted Requirements: Non-compliance with 45 CFR 75.329 and Wisconsin Department of Health Services ACPM, which may lead to ineffective purchasing practices.
  • Recommended Follow-Up: Revise the procurement policy to align with Uniform Guidance, provide staff training, and conduct annual reviews to maintain compliance.

Finding Text

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Community Health Center Program – State Identifying No. 435.151301 Wisconsin Department of Health Agreement No. 435100-G24-3919588107-90, July 1, 2023 – June 30, 2024 Agreement No. 435100-G23-3919588107-390, July 1, 2022 – June 30, 2023 Criteria or Specific Requirement – Procurement – Federal: 45 CFR 75.329. State: Wisconsin Department of Health Services ACPM and 2 CFR 200.318. Condition – The Organization’s policy governing procurement requirements for the purchase of goods or services charged to federal or state awards was not compliant with Uniform Guidance. Questioned Costs – None Context – The Organization’s procurement policy does not incorporate the following methods of procurement established by Uniform Guidance: micro-purchases, small purchase procedures, sealed bids, competitive proposals, and noncompetitive proposals. Effect – Purchases of goods or services were made that may not have been obtained in the most effective manner or in compliance with Uniform Guidance. Cause – The Organization’s procurement policy has not been updated to align with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should revise its procurement policy consistent with requirements in Uniform Guidance and provide staff education and training on the updated policy. Additionally, the Organization should review Uniform Guidance requirements on an annual basis to ensure its procurement policy remains compliant with Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Corrective Action Plan

The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters. Official Responsible for Ensuring the Corrective Action Plan: Danielle Hahn, Progressive Community Health Center Chief Financial Officer. Planned Completion Date for the Corrective Action Plan: The Organization plans to obtain Board approval for the updated procurement policy in January 2025 and will continue to monitor throughout the year.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 516671 2024-003
    Significant Deficiency
  • 516672 2024-003
    Significant Deficiency
  • 516673 2024-004
    Significant Deficiency
  • 516675 2024-005
    Significant Deficiency
  • 516676 2024-005
    Significant Deficiency
  • 516677 2024-005
    Significant Deficiency
  • 516678 2024-006
    Significant Deficiency
  • 516679 2024-006
    Significant Deficiency
  • 516680 2024-006
    Significant Deficiency
  • 516681 2024-006
    Significant Deficiency
  • 516682 2024-007
    Material Weakness
  • 516683 2024-007
    Material Weakness
  • 516684 2024-008
    Significant Deficiency
  • 516685 2024-008
    Significant Deficiency
  • 516686 2024-008
    Significant Deficiency
  • 516687 2024-008
    Significant Deficiency
  • 1093113 2024-003
    Significant Deficiency
  • 1093114 2024-003
    Significant Deficiency
  • 1093115 2024-004
    Significant Deficiency
  • 1093116 2024-005
    Significant Deficiency
  • 1093117 2024-005
    Significant Deficiency
  • 1093118 2024-005
    Significant Deficiency
  • 1093119 2024-005
    Significant Deficiency
  • 1093120 2024-006
    Significant Deficiency
  • 1093121 2024-006
    Significant Deficiency
  • 1093122 2024-006
    Significant Deficiency
  • 1093123 2024-006
    Significant Deficiency
  • 1093124 2024-007
    Material Weakness
  • 1093125 2024-007
    Material Weakness
  • 1093126 2024-008
    Significant Deficiency
  • 1093127 2024-008
    Significant Deficiency
  • 1093128 2024-008
    Significant Deficiency
  • 1093129 2024-008
    Significant Deficiency

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) $1.74M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $92,685
21.027 Coronavirus State and Local Fiscal Recovery Funds $81,304
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated and State Partnership Marketplaces $35,027
93.307 Minority Health and Health Disparities Research $13,411
93.268 Immunization Cooperative Agreements $685