Finding 523417 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-02-17
Audit: 342683
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The Clinic failed to obtain competitive bids for 4 out of 6 vendors and lacked processes to verify vendor suspension or debarment.
  • Impacted Requirements: Noncompliance with procurement standards (2 CFR 200.318-326) and suspension/debarment regulations (2 CFR Part 180).
  • Recommended Follow-Up: Conduct training for staff on procurement and debarment policies, and update procedures to ensure compliance with federal regulations.

Finding Text

Criteria: Nonfederal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Nonfederal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension and debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension,” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition: During transactional testing, the following was noted: • 93.441 – 4 out of 6 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no consistent processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. • 93.441 – 4 out of 6 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. None of the 6 vendors were suspended of debarred. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $71,963. Repeat Finding: Yes, 2022-007 and 2023-004. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic’s procurement and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: The Clinic will review the procurement standards set forth at 2 CFR part 200 and will update the procurement and purchasing policies to comply with all required purchasing standards. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 523414 2024-001
    Material Weakness Repeat
  • 523415 2024-001
    Material Weakness Repeat
  • 523416 2024-002
    Material Weakness Repeat
  • 1099856 2024-001
    Material Weakness Repeat
  • 1099857 2024-001
    Material Weakness Repeat
  • 1099858 2024-002
    Material Weakness Repeat
  • 1099859 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.441 Indian Self-Determination $891,245
93.495 Community Health Workers for Public Health Response and Resilient $597,378
93.237 Special Diabetes Program for Indians Diabetes Prevention and Treatment Projects $293,458
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation�s Health $244,243
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $77,348
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $31,609
93.053 Nutrition Services Incentive Program $30,533
93.558 Temporary Assistance for Needy Families $14,432
93.054 National Family Caregiver Support, Title Vi, Part C, Grants to Indian Tribes and Native Hawaiians $3,357