Finding 525616 (2024-001)

Procurement Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program & Health Center Infrastructure Support Assistance Listing Number: 93.224/93.527 & 93.526 Federal Award Identification Number: H8GCS47470-01-01 & C8ECS44866-01-00 Award Periods: December 1, 2022 – December 31, 2023; September 15, 2021 – September 14, 2024 Type of Finding: Immaterial noncompliance and significant deficiency in internal control over compliance Criteria: § 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. Condition: While the Organization has a procurement policy in place that meets the requirements of Uniform Guidance, the Organization did not create and retain appropriate documentation for the method of procurement utilized. Questioned Costs: 93.224/93.527: $80,057. 93.526: $38,515. Context: For one transaction selected for testing under assistance listing number (ALN) 93.224/93.527 the Organization utilized the sole source method of procurement but did not maintain documentation justifying why the use of this method was appropriate. For one transaction selected for testing under ALN 93.526 the Organization purchased medical equipment which was subject to the simplified acquisition threshold for procurement, and did not obtain an appropriate number of price quotes prior to completing the purchase. Cause: Oversight Effect: Lack of following procurement procedures could result in the Organization engaging vendors who are not the most efficient or economical. Repeat Finding: No. Recommendation: CLA recommends the Organization maintain an audit trail for all procurements. This can be done electronically for efficiency. Views of Responsible Officials: There is no disagreement with the audit finding.