Finding Text
Health Center Program Cluster
Federal Assistance Listing Nos. 93.224 and 93.527
U.S. Department of Health and Human Services
Award Nos. 6 H80CS24171-12-01, 3 H8FCS40636-01-01,
and 4 H8GCS48070-01-01
Program Year 2023
Criteria or Specific Requirement – Procurement, Suspension, & Debarment – 45
CFR 75.329
Condition – The Organization’s procurement policy established a threshold of
$25,000 for small purchase procedures rather than the $10,000 prescribed by US
DHHS. In addition, the health center did not maintain documentation demonstrating
the activities performed to demonstrate a vendor is not included on a federal
suspension or debarment list.
Questioned Costs – Unknown
Context – A sample of sixteen procurements were tested out of a population of one
hundred fifty-six transactions subject to procurement requirements. The population
sampled represented $136,774 in federal expenditures. The sample was not, and is
not intended to be, statistically valid. Of the sixteen procurements tested, four
procurements in the amount of $56,451 were not completed in accordance with
federal procurement requirements.
Effect – Purchases were made without fully adhering to federal procurement
requirements.
Cause – The Organization’s procurement policy included a small purchases
threshold that exceeds US DHHS guidance.
Identification as a Repeat Finding – Not a repeat finding
Recommendation – The Organization should revise its procurement policy to reflect
the appropriate small purchase threshold and the policy should be reviewed annually
to ensure compliance with the federal regulations.