Finding 979967 (2023-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2023
Accepted
2024-06-27
Audit: 310598
Organization: City of Hope (CA)

AI Summary

  • Core Issue: Internal control deficiencies and noncompliance in procurement processes were identified, particularly in obtaining adequate price quotations.
  • Impacted Requirements: Violations of federal procurement standards (Title 2, Part 200) regarding effective internal controls and documentation for procurement methods.
  • Recommended Follow-Up: Implement stronger internal controls and procurement procedures to ensure compliance and prevent questioned costs totaling $306,031.

Finding Text

Internal control deficiency and noncompliance over Procurement. Identification of the federal program: Research and Development Cluster See the Schedule of Findings and Questioned Costs for table. Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.303 – Internal controls. The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318(i) – General procurement standards. The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 – Methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award: (a) (2) Small purchases – (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity; (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, formal procurement methods are required. Formal procurement methods require following documented procedures. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold – (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price; (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded; (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Condition: Management did not have effective internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. During our testing over small purchase procurements, we observed management did not obtain price or rate quotations from an adequate number of qualified sources at the time of procurement. Cause: Management did not have effective internal controls in place over the compliance requirement as stated in the criteria or specific requirement section above. Effect or potential effect: Small purchase procurements, formal procurement methods, and noncompetitive procurements were not supported by effective internal controls and could potentially include unreasonable prices or rates. Questioned costs: $75,518 – Assistance Listing Number 93.398, Award Identification Number – 2 R25 CA171998 $67,225 – Assistance Listing Number 93.393, Award Identification Number – 1 R01 CA242218 $54,900 – Assistance Listing Number 93.394, Award Identification Number – 7 R01 CA202797 $48,980 – Assistance Listing Number 93.395, Award Identification Number – 2 P01 CA163205-06A1 Assistance Listing Number 93.395, Award Identification Number – 1 U19 CA264512 Assistance Listing Number 93.395, Award Identification Number – 1 R01 CA266457 Assistance Listing Number 93.396, Award Identification Number – 7 R35 CA210087 Assistance Listing Number 93.396, Award Identification Number – 1 R01 CA247550 Assistance Listing Number 93.853, Award Identification Number – 7 R01 NS106170 $41,408 – Assistance Listing Number 93.395, Award Identification Number – 1 R01 CA266457 Assistance Listing Number 93.396, Award Identification Number – 1 U01 CA275808 $12,195 – Assistance Listing Number 93.394, Award Identification Number – 1R01CA241845-01A1 $5,805 – Assistance Listing Number 93.361, Award Identification Number – 1 R21 NR019866 Questioned costs were computed by taking the total small purchase procurements that were not supported by adequate documentation of $75,518 + $67,225 + $54,900 + $48,980 + $41,408 + $12,195 + $5,805 for a total of $306,031. Context: Management did not obtain price or rate quotations from an adequate number of qualified sources at the time of procurement. Given the prior year finding was not remediated, management evaluated the entire population of small purchase and formal procurements and we tested the entire population evaluated by management. We obtained a listing of 15 small purchase procurements and 1 formal procurement. The total value of small purchase procurements was $797,099 and formal procurements was $319,047 for a total of $1,116,146. There were 7 ($306,031) out of 15 ($797,099) items where price or rate quotations from an adequate number of qualified sources were not obtained at the time of procurement. Identification as a repeat finding, if applicable: Yes – 2022-001. Recommendation: We recommend that management develop and implement effective internal controls to ensure the compliance requirements over procurements are performed. In addition, management should review the items identified as questioned costs to identify if any improper payments were made to the entity. Views of responsible officials: In response to this finding COH had/will complete the following: 1. Management provided training to reinforce current policy requirements to Research, Accounting and Procurement personnel to emphasize procurement guidelines prior to requisition submission. Training was completed on September 7 and 15, 2023. 2. Accounting reviewed sample size of federally funded procurement to ensure controls have been remediated. 3. Accounting will review the items identified as questioned costs to identify if any improper payments were made to COH.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 403506 2023-001
    Significant Deficiency
  • 403507 2023-001
    Significant Deficiency
  • 403508 2023-001
    Significant Deficiency
  • 403509 2023-001
    Significant Deficiency
  • 403510 2023-001
    Significant Deficiency
  • 403511 2023-001
    Significant Deficiency
  • 403512 2023-001
    Significant Deficiency
  • 403513 2023-001
    Significant Deficiency
  • 403514 2023-001
    Significant Deficiency
  • 403515 2023-001
    Significant Deficiency
  • 403516 2023-001
    Significant Deficiency
  • 403517 2023-001
    Significant Deficiency
  • 403518 2023-001
    Significant Deficiency
  • 403519 2023-001
    Significant Deficiency
  • 403520 2023-002
    Significant Deficiency Repeat
  • 403521 2023-001
    Significant Deficiency
  • 403522 2023-001
    Significant Deficiency
  • 403523 2023-001
    Significant Deficiency
  • 403524 2023-001
    Significant Deficiency
  • 403525 2023-002
    Significant Deficiency Repeat
  • 403526 2023-001
    Significant Deficiency
  • 403527 2023-001
    Significant Deficiency
  • 403528 2023-001
    Significant Deficiency
  • 403529 2023-001
    Significant Deficiency
  • 403530 2023-001
    Significant Deficiency
  • 403531 2023-002
    Significant Deficiency Repeat
  • 403532 2023-001
    Significant Deficiency
  • 403533 2023-001
    Significant Deficiency
  • 403534 2023-001
    Significant Deficiency
  • 403535 2023-002
    Significant Deficiency Repeat
  • 403536 2023-001
    Significant Deficiency
  • 403537 2023-001
    Significant Deficiency
  • 403538 2023-002
    Significant Deficiency Repeat
  • 403539 2023-001
    Significant Deficiency
  • 403540 2023-001
    Significant Deficiency
  • 403541 2023-001
    Significant Deficiency
  • 403542 2023-001
    Significant Deficiency
  • 403543 2023-001
    Significant Deficiency
  • 403544 2023-001
    Significant Deficiency
  • 403545 2023-001
    Significant Deficiency
  • 403546 2023-001
    Significant Deficiency
  • 403547 2023-002
    Significant Deficiency Repeat
  • 403548 2023-001
    Significant Deficiency
  • 403549 2023-002
    Significant Deficiency Repeat
  • 403550 2023-001
    Significant Deficiency
  • 403551 2023-001
    Significant Deficiency
  • 403552 2023-002
    Significant Deficiency Repeat
  • 403553 2023-001
    Significant Deficiency
  • 403554 2023-001
    Significant Deficiency
  • 403555 2023-001
    Significant Deficiency
  • 403556 2023-001
    Significant Deficiency
  • 403557 2023-001
    Significant Deficiency
  • 403558 2023-001
    Significant Deficiency
  • 403559 2023-001
    Significant Deficiency
  • 403560 2023-001
    Significant Deficiency
  • 403561 2023-001
    Significant Deficiency
  • 403562 2023-001
    Significant Deficiency
  • 403563 2023-002
    Significant Deficiency Repeat
  • 403564 2023-001
    Significant Deficiency
  • 403565 2023-001
    Significant Deficiency
  • 403566 2023-002
    Significant Deficiency Repeat
  • 403567 2023-001
    Significant Deficiency
  • 403568 2023-001
    Significant Deficiency
  • 403569 2023-001
    Significant Deficiency
  • 403570 2023-001
    Significant Deficiency
  • 403571 2023-001
    Significant Deficiency
  • 403572 2023-002
    Significant Deficiency Repeat
  • 403573 2023-001
    Significant Deficiency
  • 403574 2023-001
    Significant Deficiency
  • 403575 2023-001
    Significant Deficiency
  • 979948 2023-001
    Significant Deficiency
  • 979949 2023-001
    Significant Deficiency
  • 979950 2023-001
    Significant Deficiency
  • 979951 2023-001
    Significant Deficiency
  • 979952 2023-001
    Significant Deficiency
  • 979953 2023-001
    Significant Deficiency
  • 979954 2023-001
    Significant Deficiency
  • 979955 2023-001
    Significant Deficiency
  • 979956 2023-001
    Significant Deficiency
  • 979957 2023-001
    Significant Deficiency
  • 979958 2023-001
    Significant Deficiency
  • 979959 2023-001
    Significant Deficiency
  • 979960 2023-001
    Significant Deficiency
  • 979961 2023-001
    Significant Deficiency
  • 979962 2023-002
    Significant Deficiency Repeat
  • 979963 2023-001
    Significant Deficiency
  • 979964 2023-001
    Significant Deficiency
  • 979965 2023-001
    Significant Deficiency
  • 979966 2023-001
    Significant Deficiency
  • 979968 2023-001
    Significant Deficiency
  • 979969 2023-001
    Significant Deficiency
  • 979970 2023-001
    Significant Deficiency
  • 979971 2023-001
    Significant Deficiency
  • 979972 2023-001
    Significant Deficiency
  • 979973 2023-002
    Significant Deficiency Repeat
  • 979974 2023-001
    Significant Deficiency
  • 979975 2023-001
    Significant Deficiency
  • 979976 2023-001
    Significant Deficiency
  • 979977 2023-002
    Significant Deficiency Repeat
  • 979978 2023-001
    Significant Deficiency
  • 979979 2023-001
    Significant Deficiency
  • 979980 2023-002
    Significant Deficiency Repeat
  • 979981 2023-001
    Significant Deficiency
  • 979982 2023-001
    Significant Deficiency
  • 979983 2023-001
    Significant Deficiency
  • 979984 2023-001
    Significant Deficiency
  • 979985 2023-001
    Significant Deficiency
  • 979986 2023-001
    Significant Deficiency
  • 979987 2023-001
    Significant Deficiency
  • 979988 2023-001
    Significant Deficiency
  • 979989 2023-002
    Significant Deficiency Repeat
  • 979990 2023-001
    Significant Deficiency
  • 979991 2023-002
    Significant Deficiency Repeat
  • 979992 2023-001
    Significant Deficiency
  • 979993 2023-001
    Significant Deficiency
  • 979994 2023-002
    Significant Deficiency Repeat
  • 979995 2023-001
    Significant Deficiency
  • 979996 2023-001
    Significant Deficiency
  • 979997 2023-001
    Significant Deficiency
  • 979998 2023-001
    Significant Deficiency
  • 979999 2023-001
    Significant Deficiency
  • 980000 2023-001
    Significant Deficiency
  • 980001 2023-001
    Significant Deficiency
  • 980002 2023-001
    Significant Deficiency
  • 980003 2023-001
    Significant Deficiency
  • 980004 2023-001
    Significant Deficiency
  • 980005 2023-002
    Significant Deficiency Repeat
  • 980006 2023-001
    Significant Deficiency
  • 980007 2023-001
    Significant Deficiency
  • 980008 2023-002
    Significant Deficiency Repeat
  • 980009 2023-001
    Significant Deficiency
  • 980010 2023-001
    Significant Deficiency
  • 980011 2023-001
    Significant Deficiency
  • 980012 2023-001
    Significant Deficiency
  • 980013 2023-001
    Significant Deficiency
  • 980014 2023-002
    Significant Deficiency Repeat
  • 980015 2023-001
    Significant Deficiency
  • 980016 2023-001
    Significant Deficiency
  • 980017 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $12.63M
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $11.34M
93.172 Human Genome Research $1.13M
93.113 Environmental Health $973,111
93.493 Congressional Directives $602,039
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $322,083
93.837 Cardiovascular Diseases Research $291,657
12.420 Military Medical Research and Development $258,239
93.310 Trans-Nih Research Support $257,239
93.242 Mental Health Research Grants $247,747
93.173 Research Related to Deafness and Communication Disorders $202,409
93.859 Biomedical Research and Research Training $194,967
93.383 Public Health Nursing $177,748
93.273 Alcohol Research Programs $175,444
93.397 Cancer Centers Support Grants $175,023
93.394 Cancer Detection and Diagnosis Research $174,342
93.867 Vision Research $131,454
10.025 Plant and Animal Disease, Pest Control, and Animal Care $131,096
93.396 Cancer Biology Research $130,675
93.866 Aging Research $128,795
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $110,526
93.361 Nursing Research $103,925
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $96,038
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $81,703
93.226 Research on Healthcare Costs, Quality and Outcomes $76,209
93.393 Cancer Cause and Prevention Research $74,063
93.399 Cancer Control $67,140
93.398 Cancer Research Manpower $54,322
93.389 National Center for Research Resources $36,907
10.310 Agriculture and Food Research Initiative (afri) $30,236
93.395 Cancer Treatment Research $28,262
10.001 Agricultural Research Basic and Applied Research $25,148
93.307 Minority Health and Health Disparities Research $23,992
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $10,532
93.838 Lung Diseases Research $8,923
93.839 Blood Diseases and Resources Research $4,802
32.006 Covid-19 - Covid-19 Telehealth Program $2,696
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $2,534
93.879 Medical Library Assistance $1,500
93.103 Food and Drug Administration Research $405
93.855 Allergy and Infectious Diseases Research $248
93.865 Child Health and Human Development Extramural Research $-246
93.121 Oral Diseases and Disorders Research $-8,726