Finding 540578 (2024-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-29

AI Summary

  • Core Issue: The Organization failed to follow its own procurement policy for federal awards, leading to non-compliance.
  • Impacted Requirements: Procurement guidelines under 45 CFR 75.329 were not met, including vendor selection and documentation for exclusions.
  • Recommended Follow-Up: Review and update the procurement policy, provide staff training, and conduct annual policy reviews to align with Uniform Guidance.

Finding Text

Health Center Program Cluster Assistance Listing Nos. 93.224 and 93.527 U.S Department of Health and Human Services Award Nos. 6 H80CS26514-10-02, 3 H8FCS40655-01-01, 4 H8GCS47538-01-01, 1 H8LCS50783-01-00 Criteria or Specific Requirement – Procurement – 45 CFR 75.329 Condition – The Organization did not follow its policy governing procurement requirements for the purchase of goods and services charged to federal awards. Questioned Costs – Unknown Context – A sample of one procurement was tested out of a population of six procurements totaling $605,943. The sample was not, and is not intended to be, statistically valid. The one procurement tested in the amount of $18,277 was not completed in accordance with the Organization’s procurement policy for vendor selection. The Organization’s procurement policy does not specify the micro-purchase limit and ongoing monitoring procedures of suspended and debarred vendors is not defined. Lastly, a sample of one vendor was tested out of a population of four vendors with contracts exceeding $25,000. The Organization did not retain documentation to support initial verification of vendor against the exclusions list. Effect – Purchases were made that did not adhere to the Organization’s procurement policy. Cause – The Organization did not comply with their federal procurement policy. Identification as a repeat finding, if applicable – Not a repeat finding. Recommendation – The Organization should review its procurement policy and ensure proper staff education on the policy is established. In addition, the Organization should review the policy on an annual basis to ensure it is consistent with Uniform Guidance.

Corrective Action Plan

During 2023, the Company procured temporary staffing for Certified Nursing Assistants (CNAs) to meet operational needs. The Human Resources (HR) department reached out to multiple staffing agencies to secure qualified personnel. However, many agencies did not have available staff at the time of the request, and as a result, the Company ultimately selected the staffing firm that could meet its immediate needs in terms of staffing availability. It is important to note that a formal Request for Proposal (RFP) process was not conducted for this procurement. Additionally, HR did not formally document the details of the outreach made to the agencies that were unable to provide staffing. While this decision was made in the best interest of ensuring that operational needs were met without delay, the lack of formal documentation and the absence of an RFP process represent areas where the Company’s procurement practices could be improved to align with best practices for vendor selection and documentation. Going forward, will implement enhanced procedures for procurement processes, including the documentation of agency outreach and the consideration of more formalized vendor selection methods, such as RFPs, to ensure transparency and strengthen internal controls. This will be the responsibility of the Finance Director and CFO and will begin in April 2024 and will be complete by June 30, 2025.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 540579 2024-003
    Material Weakness
  • 540580 2024-003
    Material Weakness
  • 540581 2024-003
    Material Weakness
  • 540582 2024-003
    Material Weakness
  • 540583 2024-004
    Material Weakness
  • 540584 2024-004
    Material Weakness
  • 540585 2024-004
    Material Weakness
  • 540586 2024-004
    Material Weakness
  • 540587 2024-004
    Material Weakness
  • 540588 2024-005
    Material Weakness
  • 1117020 2024-003
    Material Weakness
  • 1117021 2024-003
    Material Weakness
  • 1117022 2024-003
    Material Weakness
  • 1117023 2024-003
    Material Weakness
  • 1117024 2024-003
    Material Weakness
  • 1117025 2024-004
    Material Weakness
  • 1117026 2024-004
    Material Weakness
  • 1117027 2024-004
    Material Weakness
  • 1117028 2024-004
    Material Weakness
  • 1117029 2024-004
    Material Weakness
  • 1117030 2024-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $1.17M
93.224 Community Health Centers $1.12M
93.224 American Rescue Plan Act for Health Centers $595,028
93.527 Fy 2023 Expanding Covid-19 Vaccination $100,997
93.959 Block Grants for Prevention and Treatment of Substance Abuse $10,797
93.527 Fy 2024 Covid Bridge Access $5,850
93.527 Fy 2018 Aims Supplemental Funding $-55,112