Finding 574130 (2024-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-08-21
Audit: 364705
Organization: Legacy Medical Care Inc. (IL)

AI Summary

  • Core Issue: Legacy failed to keep proper documentation for procurement methods used, leading to a material weakness in internal controls.
  • Impacted Requirements: This violates 2 CFR section 200.320, which mandates documentation for procurement methods, especially for purchases above the micro-purchase threshold.
  • Recommended Follow-Up: Legacy should adhere to its procurement policies and consider qualifying multiple vendors to ensure fair competition and compliance.

Finding Text

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds; Health Center Program Cluster Assistance Listing Number: 21.027; 93.224/93.527 Pass-Through Entity: Cook County Department of Public Health, N/A Pass-Through Number: None; N/A Award Periods: May 1, 2023-November 30, 2026; July 1, 2021 – June 30, 2023. Type of Finding: Material weakness in internal control over compliance Criteria: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Legacy did not maintain appropriate documentation to support the procurement method utilized for procurements selected for testing. Questioned Costs: Unknown. Context: One (1) of two (2) transactions selected for testing within 21.027 and three (3) of three (3) transactions selected for testing within 93.224/93.527. Cause: Legacy did not maintain appropriate documentation based on the method of procurement utilized. Effect: Legacy may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: Yes. Prior Year Finding: 2023-005. Recommendation: We recommend Legacy consistently follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Action taken in response to finding: •LMC staff will receive further training in the use of sole source documentation, and the established policies and procedures for purchasing and procurement. •LMC staff responsible for purchasing and agreements will follow the established policy and procedures for procurement. •LMC staff will develop and maintain tracking mechanisms related to the methodology used for each noncompetitive procurement. Name(s) of the contact person(s) responsible for corrective action: Melissa D’Onorio, CEO, and Donna Landy, CFO. Planned completion date for corrective action plan: 07/14/2025

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 574129 2024-002
    Material Weakness Repeat
  • 574131 2024-004
    Material Weakness
  • 574132 2024-005
    Significant Deficiency
  • 574133 2024-003
    Material Weakness Repeat
  • 574134 2024-005
    Significant Deficiency
  • 1150571 2024-002
    Material Weakness Repeat
  • 1150572 2024-003
    Material Weakness Repeat
  • 1150573 2024-004
    Material Weakness
  • 1150574 2024-005
    Significant Deficiency
  • 1150575 2024-003
    Material Weakness Repeat
  • 1150576 2024-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $294,199
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $85,710
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $37,364
93.322 Cdc Partnership: Strengthening Public Health Laboratories $33,792
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges $18,289
93.268 Immunization Cooperative Agreements $14,950
93.527 Grants for New and Expanded Services Under the Health Center Program $8,823