Finding Text
Finding 2018 - 001 Procurement, Suspension & Debarment (I) Significant Deficiency in Internal Controls over
Compliance
Identification of the Federal Program: U.S. Department of Health and Human Services; Health Clinic Program
Cluster; CFDA 93.224: 18H80CS31240.
Criteria or Specific Requirement: Non-federal entities must follow the procurement standards set out at 2 CFR
Sections 200.318 through 200.326. They must use their own documented procedures, which reflect applicable state
and local laws and regulations, provided that the procurements conform to applicable federal statues and the
procurement requirements identified in 2 CFR Part 200 as described above.
Finding/Condition: The procurement policies and procedures were found lacking as to the bidding and retaining
process. We could not locate certain files indicating that the procurement requirements had been followed. In
addition, we could not locate certain files indicating the debarment procedures had been properly followed per the
requirements.
Cause: Management lack of time to establishing a policy and procedure regarding this requirement.
Effect: The lack of policies and procedures in this area may cause the Clinic to be out of compliance with this
procurement, suspension and debarment requirement. A lack of competitive bidding may overstate allowable costs
and a lack of debarment procedures may allow debarred vendors in providing material, supplies and services.
Questioned Cost: None
Recommendation: The Clinic should establish sound policies and procedures which conform to federal requirements
for procurement, suspension and debarment.
Views of Responsible Officials and Corrective Action Plan: See corrective action plan.