Finding Text
Finding No.: 2022-008
Federal Agency: U.S. Department of Health and Human Services
AL Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases
Federal Award No.: NU50CK000558
Questioned Costs: $660,990
Area: Procurement and Suspension and Debarment
Criteria:
Section 200.317 of 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards states that, when procuring property and services under a
Federal award, a state must follow the same policies and procedures it uses for procurements from
its non-Federal funds.
Procurement Code states the following:
(a) Section 124 - unless otherwise authorized by law, all Government contracts shall be awarded by
competitive sealed bidding.
(b) Section 127 - procurement of goods and services not exceeding $25,000 may be made in
purchase procedures are those relatively simple and informal methods for securing services,
Banking and Postal Services has previously declared that if small purchase procedures are used,
price or rate quotations shall be obtained from three qualified sources.
(c) Section 128 - a contract may be awarded for a supply, service, or construction item without
competition when it is determined in writing that there is only one source for the required supply,
service, or construction item.
Condition:
For 4 (or 33%) of 12 procurement transactions tested, aggregating $1,041,946 of $1,858,109 in total
transactions subject to procurement requirements, no procurement file was provided.
Item # Encumbrance # Ref # Amount
QC reported at
this Finding
1 C15761 767993 $ 135,186 $ -
2 C15945 785944 600,370 600,370
3 C16477 009097 50,620 50,620
4 F01223 793869 10,000 10,000
$ 796,176 $ 660,990
Cause:
RepMar did not enforce adequate internal control policies and procedures over documentation of
the procurement process to satisfy compliance with applicable procurement requirements.
Effect:
RepMar is in noncompliance with applicable procurement requirements. The reportable questioned
cost is $650,990 (COVID) and $10,000 (non-COVID).
Recommendation:
Responsible personnel should require that documentation be adequate to comply with applicable
procurement requirements. Specifically, documentation should indicate the history of procurement,
including the rationale for contractor or vendor selection.
Views of Responsible Officials:
We partially agree with the finding and provide details in our Corrective Action Plan.