Finding Text
Federal Agency: Department of Health and Human Services
Federal Program Name: Substance Abuse and Mental Health Services Projects of Regional and
National Significance
Assistance Listing Number: 93.243
Federal Award Identification Number and Year: 1H79SM087513-01 - 2024
Award Period: September 30, 2023 through September 29, 2027
Type of Finding:
• Other Matters
Criteria or specific requirement: According to 2 CFR 200.318, non-federal entities must have and
use documented procurement procedures that reflect applicable state and local laws and regulations,
and conform to federal law and the standards identified in 2 CFR 200.318 through 2 CFR 200.327.
Condition: During our review of the organization's procurement processes, it was noted that the
organization does not have a procurement policy that complies with federal requirements. Specifically,
the policy does not address key elements such as competition, cost or price analysis, and
documentation requirements as outlined in federal regulations.
Questioned costs: None
Context: Policies exist, but do not meet requirements. There are no requirements to retain
documentation related to comparison or analysis prior to purchase or procurement.
Cause: The absence of a compliant procurement policy appears to be due to a lack of awareness of
the specific federal requirements and the absence of a formal process to review and update
organizational policies to ensure compliance.
Effect: Without a procurement policy that complies with federal requirements, the organization is at risk
of non-compliance with grant conditions, which could lead to questioned costs, potential disallowance
of expenditures, and jeopardize future funding opportunities.
Recommendation: We recommend that the Organization develop and implement a procurement policy
that complies with federal requirements, including provisions for competition, cost or price analysis, and
proper documentation.
Views of responsible officials: There is no disagreement with the audit finding.