Finding 582943 (2022-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-12-26
Audit: 8469
Organization: Palo Alto County Hospital (IA)

AI Summary

  • Core Issue: The Health System lacks a documented procurement policy that meets federal requirements, leading to insufficient support for vendor selections over the micro-purchase threshold.
  • Impacted Requirements: Compliance with the Code of Federal Regulations section 200.320 and Federal Acquisition Regulations (FAR) regarding procurement procedures and documentation.
  • Recommended Follow-up: Develop and implement a procurement policy that aligns with federal regulations and ensure proper documentation is maintained for vendor procurement related to federal grants.

Finding Text

Federal agency: U.S. Department of Health and Human Services Federal program title: Rural Communities Opioid Response Program – Medication Assisted Treatment (MAT) Expansion and COVID-19 Rural Health Clinic Vaccine Confidence Assistance Listing Number: 93.912 Award Period: September 1, 2019 through August 31, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations section 200.320 states the non-Federal entity must have and use documented procurement procedures following specific requirements for different methods of procurement depending on size and type of purchase. Thresholds for these categories (micro-purchase, simplified acquisition threshold) refer to using the Federal Acquisition Regulations (FAR), unless a different threshold has been specifically approved. Specifically, under FAR multiple quotes are generally required for purchases over the micro-purchase threshold, or documentation should be maintained explaining why multiple quotes were not obtained. Condition: During our testing, we noted the Health System did not have a properly documented procurement policy that met the federal requirements. As a result there were vendors over the micro purchase threshold that were tested where retained documentation was not sufficient to support procurement method or noncompetitive procurement in line with federal requirements. Questioned costs: None Context: The Health System maintained detailed records of eligible uses of federal funds for tracking and required reporting purposes. Eligible expenditures were reviewed by the CFO and followed standard organizational internal control processes (i.e., AP), but ultimately did not follow a procurement policy in line with Uniform Guidance requirements. Cause: The Health System has not previously received federal awards in an amount sufficient to require an audit under Uniform Guidance. Therefore, more formal controls and policies around the use of federal awards had not been in place. Effect: The lack of documented procurement policies over these compliance requirements provides an opportunity for noncompliance. Repeat finding: No Recommendation: We recommend the Health System create and implement a procurement policy that meets the requirements of federal regulations. The Health System should also maintain documentation to support procurement method used and compliance with policy when procuring vendors for federal grant funded projects. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 6497 2022-003
    Material Weakness Repeat
  • 6498 2022-004
    Significant Deficiency
  • 6499 2022-005
    Significant Deficiency
  • 6500 2022-003
    Material Weakness Repeat
  • 6501 2022-004
    Significant Deficiency
  • 6502 2022-005
    Significant Deficiency
  • 582939 2022-003
    Material Weakness Repeat
  • 582940 2022-004
    Significant Deficiency
  • 582941 2022-005
    Significant Deficiency
  • 582942 2022-003
    Material Weakness Repeat
  • 582944 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.697 Covid-19 Testing for Rural Health Clinics $271,754
93.498 Provider Relief Fund $175,333
93.301 Small Rural Hospital Improvement Grant Program $94,306
21.019 Coronavirus Relief Fund $68,358
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $65,347
93.889 National Bioterrorism Hospital Preparedness Program $6,232