Finding Text
Finding 2023-002
Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: Department of Health and Human Services (HHS)
Pass-Through: State of Washington Department of Health (DOH)
Program Title: HIV Prevention Activities Health Department
Assistance Listing Number: 93.940
Award Number: CBO27200; CBO28119; 10248 PREV
Award Period: July 01, 2022 through August 31, 2023; July 01, 2023 through
December 31, 2023; April 01, 2023 through March 31, 2024
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D ‐ Post Federal Award Requirements, Sections 200.318 through 200.320, require that a non-federal entity have documented procurement procedures that provide for full and open competition and follow the procurement methods required by Subpart D of 2 CFR Part 200.
Condition/Context for Evaluation
Although the Organization has a procurement policy, the policy does not cover the requirements in Subpart D which include the thresholds for micro-purchase awards, small purchases, and formal procurement methods such as sealed bids, proposals, and noncompetitive procurement. Nor does the policy cover solicitation procedures for procurements.
Cause
The Organization's procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance.
Effect or Potential Effect
The absence of a policy that fully conforms to the Uniform Guidance does not assure open and free competition among suppliers.
Questioned Costs
None.
Repeat Finding
No.
Recommendation
We recommend the Organization implement measures to ensure that its procurement policy reflect applicable requirements in 2 CFR Part 200 Subpart D.
Views of Responsible Officials and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.