Finding Text
U.S. Department of Health and Human Services Passed through Health Research &
Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and
Improving Health Globally: Building and Strengthening Public Health Impact, Systems,
Capacity and Security
Procurement
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal
entities other than states must follow when operating federal programs and the procurement
procedures required depending on the amount of the transaction. The Organization is required
to create a written procurement, suspension, and debarment policy that complies with
applicable federal requirements and to follow this policy when procuring goods and services.
The Organization is also required to retain documentation supporting performance of a price
analysis and open competition.
Condition: The Organization’s procurement policy does not contain all provisions required by
Appendix II to 2 CFR Part 200. Additionally, there was no documentation retained supporting a
price analysis over the transactions tested.
Cause: The Organization has limited staffing and did not have proper controls in place relating to
review of the procurement policy.
Effect: The Organization did not ensure that the procurement policy was complete and accurate.
Questioned Costs: None reported.
Context: A nonstatistical sample of 4 out of 9 procurement transactions were selected for
testing, which accounted for $175,792 of $370,234 qualified expenditures.Repeat Finding from Prior Years: No
Recommendation: We recommend the Organization follow control processes implemented
which includes updating the procurement policy and documenting the performance of required
procurement procedures.
Views of Responsible Officials: Management agrees with the finding.