Finding Text
Finding Reference: 2023-001 – I. Procurement, Suspension and Debarment
Information on the Federal Program:
Grantor: Department of the Treasury
Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Criteria or Specific Requirement:
For compliance requirement I.1 Procurement, Nuvance Health and Subsidiaries (the “System”) must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. The System may also use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition:
As part of our testing over the operating effectiveness of internal controls over the Procurement compliance requirement, we noted that the System did not have a procurement policy that conforms to all applicable federal laws, State and Local Fiscal Recovery Funds Regulations, and the standards contained in the Uniform Guidance, as applicable, when purchasing services with the federal funds related to the program.
Cause:
The System did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving federal funds related to the program.
Effect or Potential Effect:
Purchasing of goods and/or services with program funds may not be in compliance with the Uniform Guidance.
Questioned Costs:
Not applicable.
Context:
The System’s internal procurement policy has not been reviewed to incorporate all of the required provisions within 2 CFR 200.318 through 200.327.
Identification as a repeat finding:
This finding is not a repeat finding from the prior year.
Recommendation:
The System should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds.
View of responsible officials:
Management concurs with this finding and is currently drafting a procurement policy to incorporate the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds.