Finding 606558 (2022-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-04-20
Audit: 34568
Auditor: Forvis LLP

AI Summary

  • Core Issue: The Organization lacked documentation to support procurement activities for federal awards, violating procurement requirements.
  • Impacted Requirements: Non-compliance with 45 CFR 75.329 regarding proper vendor selection and procurement documentation.
  • Recommended Follow-Up: Review and educate staff on procurement policy; ensure annual policy reviews for alignment with Uniform Guidance.

Finding Text

Health Center Program Cluster ? Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00881-20 and 1 H8FCS41120-01 Program Year 2022 Criteria or Specific Requirement ? Procurement ? 45 CFR 75.329 Condition ? The Organization did not maintain documentation supporting procurement requirements for the purchase of goods or services charged to federal awards. Questioned cost ? None Context ? Documentation was not originally maintained by the Organization to support that proper procurement procedures in accordance with the Organization?s policy were followed related to vendor selection. Documentation was later compiled in response to audit inquiries. Effect ? The Organization did not have documentation supporting the procurement activities completed. Cause ? The Organization was not properly following the documentation requirements of their federal procurement policy. Identification as a repeat finding, if applicable ? Not a repeat finding. Recommendation ? The Organization should review its procurement policy and ensure proper staff education on the policy is established. In addition, the Organization should review the policy on an annual basis to ensure it is consistent with Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions ? ? Vice President of Support Services was hired to lead the procurement process. ? The Procurement Department implemented the use of bids, as they foster competition whenever feasible. All procurement is conducted in a competitive manner with open access to acceptable suppliers. ? The VP of Support Services oversees the procurement policy and will ensure future adherence. The CFO, Talia Peterson, and VP of Support Services, Susan Banning, are responsible for this corrective action plan. Implementation of the above items have already begun and will be completed by August 2023.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 30116 2022-002
    Significant Deficiency
  • 30117 2022-002
    Significant Deficiency
  • 30118 2022-002
    Significant Deficiency
  • 606559 2022-002
    Significant Deficiency
  • 606560 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Covid-19 - Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $8.55M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $4.84M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $2.25M
93.914 Hiv Emergency Relief Project Grants $800,355
93.498 Provider Relief Fund $591,586
93.059 Training in General, Pediatric, and Public Health Dentistry $549,551
93.917 Hiv Care Formula Grants $164,299
93.461 Covid-19 Testing for the Uninsured $65,196
93.917 Covid-19 - Hiv Care Formula Grants $17,366
93.914 Covid-19 - Hiv Emergency Relief Project Grants $13,200