Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004)
Condition:
During our review of the Coalition's Policies and Procedures, we determined that the Coalition's
Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327
In response to the finding related to non-compliance with procurement policies and procedures under Uniform Guidance 2 CFR §200.317 – §200.327, the Nebraska Urban Indian Health Coalition (NUIHC) is committed to ensuring full compliance with all applicable federal, state, local, and tribal procurement requirements.
To address this finding and strengthen internal practices, the Coalition will implement the following corrective actions:
1. Procurement Policy Review with External Expertise:
NUIHC has contracted with an external consultant with expertise in federal procurement regulations to assist in conducting a thorough review of the organization’s current procurement policies and procedures. This partnership will help ensure that all updates reflect the specific requirements of 2 CFR §200.317 – §200.327 and incorporate best practices in compliance, documentation, and oversight.
2. Update and Alignment of Procedures:
With the support of the external contractor, NUIHC will update detailed procurement procedures to ensure they align with Uniform Guidance and any applicable state, local, or tribal procurement laws. Clear step-by-step procedures will be documented for each procurement method (e.g., micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals).
3. Ongoing Education and Training:
NUIHC will implement a continued education and training program for all staff involved in procurement activities. In addition to the initial training on updated policies, refresher training will be offered annually and included as part of new employee onboarding. This will ensure sustained awareness of procurement responsibilities and regulatory compliance.
4. Internal Controls and Review Process:
A formal internal control process will be implemented to verify compliance with updated procurement policies. This includes a procurement checklist, mandatory pre-approval protocols, and supporting documentation requirements for every procurement action.
5. Monitoring and Quarterly Compliance Checks:
The Coalition will continue conducting quarterly internal audits of procurement activities to ensure adherence to policy, detect potential issues early, and implement timely corrective actions. Findings will be reported to leadership and the Board of Directors as part of ongoing compliance oversight.
Timeline for Implementation:
• External Consultant Engagement: Completed – May 2025
• Policy and Procedure Review: To be completed by July 31, 2025
• Initial Staff Training: To be conducted by August 15, 2025
• Internal Controls & Monitoring: To be fully implemented by August 31, 2025
• Ongoing Training and Quarterly Reviews: Begin Q3 2025 and continue thereafter
Anticipated Full Compliance Date: August 31, 2025
Corrective Action Plan Finding 2024-005 – procurement Policy (Repeat Finding 2023-004)
Responsible Party: Chief Financial Officer, Carlett Gregory