Finding 561216 (2024-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-05-21

AI Summary

  • Core Issue: The organization lacked a written procurement policy before October 2024, leading to noncompliance with federal regulations.
  • Impacted Requirements: Compliance with Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations.
  • Recommended Follow-Up: Ensure adherence to the new procurement policy implemented in October 2024 to avoid future compliance issues.

Finding Text

Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.847, 93.867, & 93.103 Federal Award Identification Number and Year: Various Award Period: January 1, 2024, through December 31, 2024 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires organizations to have a written procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. Condition: Prior to October 2024 the Organization did not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations. Questioned Costs: None Context: The new policy was implemented in October 2024. Our testing concluded that the new policy covers the requirements noted in Section 200.318 of the Code of Federal Regulations. In addition, 8 of the transactions in our sample for procurement testing fall under the new policy, and we noted no instances of noncompliance in those 8 transactions. This finding is recurring solely because the new policy was not in place prior to October 2024. Cause: The new policy was being developed during 2024 Effect: Noncompliance with federal procurement requirements Repeat Finding: Yes, 2023-001 Recommendation: We recommend that the Organization follow the new policy going forward. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.

Corrective Action Plan

Department of Health and Human Services 2024-001 Procurement Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Organization had a procurement policy in place for the entire year, until October 1, 2024 it was noncompliant with the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. The new policy was implemented on October 1, 2024 and there were no instances of noncompliance after this date. It is the opinion of the organization that this finding has therefore already been resolved. Name(s) of the contact person(s) responsible for corrective action: Erica Vogt, CFO Planned completion date for corrective action plan: Already resolved

Categories

Procurement, Suspension & Debarment Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 561217 2024-001
    Material Weakness Repeat
  • 561218 2024-001
    Material Weakness Repeat
  • 561219 2024-001
    Material Weakness Repeat
  • 561220 2024-001
    Material Weakness Repeat
  • 561221 2024-001
    Material Weakness Repeat
  • 561222 2024-001
    Material Weakness Repeat
  • 561223 2024-001
    Material Weakness Repeat
  • 561224 2024-001
    Material Weakness Repeat
  • 1137658 2024-001
    Material Weakness Repeat
  • 1137659 2024-001
    Material Weakness Repeat
  • 1137660 2024-001
    Material Weakness Repeat
  • 1137661 2024-001
    Material Weakness Repeat
  • 1137662 2024-001
    Material Weakness Repeat
  • 1137663 2024-001
    Material Weakness Repeat
  • 1137664 2024-001
    Material Weakness Repeat
  • 1137665 2024-001
    Material Weakness Repeat
  • 1137666 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.867 Vision Research $726,861
93.103 Food and Drug Administration Research $202,888
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $99,801