Finding Text
WIC Special Supplemental Nutrition Program for Women, Infants, and Children
Assistance Listing No. 10.557
U.S. Department of Agriculture
Criteria or Specific Requirement – Procurement (45 CFR 200.318-200.326)
Condition - The Health System, prior to fiscal year 2025, did not have a comprehensive procurement policy that is in line with Uniform Guidance requirements. In addition, the Health System entered into various professional services contracts for marketing, advertising, and information dissemination that do not exceed the simplified acquisition threshold and are considered micro-purchases, but did not maintain appropriate documentation to document the price reasonableness based on research, experience, and purchase history to support its procurement decisions.
Questioned Costs - None
Context - We tested one out of a total of four contracts that were considered micro-purchases. The sample was not intended to be, and was not, a statistically valid sample. During our testing of procurement requirements, the two vendor contracts tested over the micro-purchase threshold did not have appropriate documentation to evidence the basis of vendor selection (documentation of the price reasonableness based on research, experience, and purchase history).
Effect - Micro-purchases were made without appropriate documentation to comply with Uniform Guidance requirements.
Cause - The Health System did not have a comprehensive procurement policy that is in line with Uniform Guidance requirements. Adequate supporting documentation on the procurements were not obtained or maintained within vendor files and vendor contracts do not contain the necessary contract provision and language required by the Uniform Guidance.
Repeat Finding - Yes
Recommendation - We recommend the Health System revisit controls over this compliance requirement to ensure that appropriate documentation is gathered and retained within its procurement files to support all Federally funded purchasing decisions. We also recommend the Organization perform a comprehensive review of its procurement policy and ensure that it is in compliance and in-line with the procurement requirements of the Uniform Guidance.
Views of responsible officials and planned corrective actions – The Organization has developed and implemented a policy and checklist to maintain written documentation of vendor selection and procurement process, along with the review and approval process required under the Uniform Guidance requirements.