Finding Text
2022 – 001 Procurement
Federal Agency: U.S. Department of Health and Human Services
Federal Program: COVID-19: FY 2020 Health Center Program Look-Alikes: Expanding Capacity for Coronavirus Testing and COVID-19: American Rescue Plan Act Funding for Look-Alikes
AL Number: 93.224 & 93.527
Award Period: 7/1/21 - 6/30/22
Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance
Criteria or Specific Requirement
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions.
Condition and Context
We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. During our testing, we noted the Organization’s procurement policy did not meet the requirements defined by 2 CFR 200.
Effect
The auditor noted an instance of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors.
Questioned Costs
None identified.
Cause
The Organization lacks a uniform Procurement, Suspension & Debarment policy that is in compliance with the Federal regulations and/or the terms and conditions of the Federal award.
Recommendation
We recommend the Organization review and update its procurement policy to ensure the policy meets the 2 CFR Part 200 Procurement requirements.
Views of Responsible Officials
The Organization will compare our procurement policy to the procurement requirements defined by 2 CFR 200 and update the policy accordingly. This will be performed by Andrea Cortez, Chief Operating Officer, and Andrew Shahidi, Chief Financial Officer, in the next 45 days and the revised policy will be submitted to the Board of Directors for approval at the March 27, 2024 meeting.