Finding 560051 (2024-002)

Federal Agency: U.S. Department of Health and Human Services Federal Program: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects – ALN 93.048 Criteria Uniform Guidance 2 CFR 200, Section 200.318 requires the Organization to maintain and use its own documented procurement procedures which reflect applicable federal, state and local laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in 2 CFR 200, Sections 200.318 through 200.327. Condition and Context The Organization’s current documented procurement policy does not contain all the required elements identified within the Uniform Guidance. Questioned Costs None Cause The Organization was not aware of all the procurement requirements under the Uniform Guidance. Effect or Potential Effect The Organization may procure goods and services that do not comply with the requirements under the Uniform Guidance, including not following required specific procurement methods, conducting procurement transactions that do not provide full and open competition, and entering into transactions that have conflicts of interest, among others. Recommendation The Organization should adopt a formal procurement policy that complies with 2 CFR 200, Sections 200.318 through 200.327. Views of Responsible Officials and Planned Corrective Action Management will review the requirements under the Uniform Guidance relating to procurement and establish a formal policy and related procedures to comply with those requirements.