Finding Text
Assistance Listing Number: 93.048
Program Name: Special Programs for the Aging, Title IV and Title II Discretionary Projects
Federal Agency: U.S. Department of Health and Human Services
Federal Award Year: March 31, 2023
Compliance Requirement: Procurement
Criteria: 2 CFR 215.43 states that all procurement transactions shall be conducted in a manner to provide, to the maximum extent practical, open and free competition. The recipient shall be alerted to organizational conflict of interest as well as noncompetitive practices among contractors that may restrict or eliminate competition or
otherwise restrain trade. Awards shall be made to the bidder or offer or whose bid or offer is responsive to the solicitation and is most advantageous to the recipient, price, quality, and other factors considered. Solicitations shall clearly set forth all requirements that the bidder or offeror shall fulfill in order for the bid or offer to be
evaluated by the recipient. Any and all bids or offers may be rejected when it is in the recipient’s interest to do so. Management requires that quotes be obtained for all small purchases.
Condition and Context: For one out of eight transactions tested, the Organization did not maintain a record of having obtained quotes.
The sample was not, nor was it intended to be, a statistically valid sample.
Cause: The Organization did not receive or maintain evidence of receiving quotes for the purchase in question.
Effect: Potential exists that purchased goods are not at a fair and competitive price.
Questioned Costs: None.
Recommendation: We recommend that Organization management maintains adequate records of bids and quotes in a centralized repository to ensure compliance with 2 CFR 215.43.
Response: There is no disagreement with the finding and recommendation noted above. The Organization had a long relationship with the vendor in question and the vendor has always provided a high quality service at an informally determined reasonable price. In our opinion, the Organization’s informal processes has always accomplished the procurement objective. The Organization will implement a procedure that includes all vendors that fall within the compliance guidelines of 2 CFR 215.43 in accordance with the recommendation described above. As of this writing, we are confident that future purchases will be made in conformance with this policy and that we will have a practical centralized repository solution by the time our March 31, 2024 fiscal year ends.
Person Responsible for Corrective Action: Executive Director