Finding Text
Finding: Procurement and Suspension & Debarment
Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury Passed-Through from Colorado Mental Health Services
Award Year: 2024 Award Number: CMS 179319
Criteria: In accordance with 2 CFR 200.318, non-Federal entities must have and use
documented procurement procedures, consistent with State and local regulations and
the standards of this section, for the acquisition of property or services required under a
Federal award or subaward. The non-Federal entity's documented procurement
procedures must conform to the procurement standards identified in 2 CFR 200.317
through 200.327. In accordance with 2 CFR Part 180, contracts cannot be entered with
certain parties that are debarred, suspended, or otherwise excluded from receiving or
participating in federal awards.
WellPower's procurement policy requires the following:
A. For purchases between $10,000 and $49,999 WellPower is required to obtain a
minimum of two quotes and for purchases exceeding $50,000 WellPower is required to
obtain three written quotes or bids. All bids and quotes received must be attached to the
purchase requisition.
B. For purchases using sponsored project funds, such as federal grants, the policy
states that procurement has to be made in accordance with grant's terms and
conditions. To be compliant with the grant and in accordance with 2 CFR Part 180,
WellPower must verify that the vendor selected for procurement is not suspended or
debarred when procurement or non-procurement transaction exceeds or is equal to
$25,000.
Condition: WellPower did not obtain price quotes related to a purchase of $61,526,
which fell within the small purchases threshold. In addition, WellPower did not retain
support for a check of suspension and debarment.
Questioned Costs: $61,526
Context: We tested one out of five of WellPower's small procurement purchases, which
was related to an information technology purchase during fiscal year 2024 in the amount
of $61,526 and noted the above issue. A non-statistical sampling methodology was used
to select the sample.
Effect: WellPower was not in compliance with its procurement and suspension and
debarment policies and the Uniform Guidance.
Cause: WellPower did not follow its internal control policies by obtaining adequate
documentation to support its procurement decisions and did not retain timely suspension
and debarment checks.
Identification as a repeat finding: Not a repeat finding
Recommendation: We recommend that WellPower follows its procurement procedures
in accordance with 2 CFR 200.317 through 200.327 and suspension and debarment
policies and requirements in accordance to 2 CFR Part 180 for the acquisition of
property or services as required under a Federal award or sub-award. We also
recommend that WellPower review its procurement policy to ensure that it complies with
Uniform Guidance. In addition, in order to facilitate compliance with its internal control
policies, we recommend training for the procurement department and other authorized
purchasers within WellPower.
Views of responsible officials: WellPower agrees with the finding. See separate
report for planned corrective actions.