Finding 986 (2023-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2023-10-31
Audit: 1866
Organization: Northwest Health Services, Inc. (MO)
Auditor: Forvis LLP

AI Summary

  • Core Issue: The Organization failed to follow its own procurement policy for federal awards, leading to non-compliance.
  • Impacted Requirements: This affects procurement practices under 45 CFR 75.329, with three out of five tested purchases totaling $503,098 not meeting policy standards.
  • Recommended Follow-Up: Review and update the procurement policy, provide staff training, and conduct annual reviews to align with Uniform Guidance.

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 H80CS00671-2204, 1 C14CS39842-01-04, and 1 H8FCS41342-01-00 Program Year 2023 Criteria or Specific Requirement – Procurement – 45 CFR 75.329 Condition – The Organization did not follow its policy governing procurement requirements for the purchase of goods or services charged to federal awards. Questioned Costs – Unknown Context – A sample of five procurements were tested out of a population of thirty-two procurements totaling $3,526,022. The sample was not, and is not intended to be, statistically valid. Of the five procurements tested, three procurements in the amount of $503,098 were not completed in accordance with the Organization’s procurement policy for vendor selection. Effect – Purchases were made that did not adhere to the Organization’s procurement policy. Cause – The Organization did not comply with their federal procurement policy. Identification as a Repeat Finding – Repeat finding 2022-003. Recommendation – The Organization should review its procurement policy and ensure proper staff education on the policy is established. In addition, the Organization should review the policy on an annual basis to ensure it is consistent with the Uniform Guidance.

Corrective Action Plan

We concur with this finding. Management recognizes the importance of complying with NHS’ federal procurement policy. Procurement policy and procedure was thoroughly reviewed and revised accordingly when compared to the federal procurement policy. The procurement policy was approved by Board of Directors on November 29, 2022. When finding 2022-003 was presented to us by the auditors in August 2022, the procurements referred to in finding 2023-001 had already taken place. Going forward, the procurement policy will be reviewed on a regular basis to ensure that personnel involved in procurement are educated with regards to the procurement policy and procedures. Additionally, the procurement policy will be reviewed on an annual basis to ensure it is consistent with the Uniform Guidance. Contact Person: Tina Harris, CFO Completion Date: November 29, 2022

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 987 2023-001
    Material Weakness Repeat
  • 988 2023-001
    Material Weakness Repeat
  • 989 2023-001
    Material Weakness Repeat
  • 577428 2023-001
    Material Weakness Repeat
  • 577429 2023-001
    Material Weakness Repeat
  • 577430 2023-001
    Material Weakness Repeat
  • 577431 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $4.01M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $2.54M
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $840,450
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $377,252
93.778 Medical Assistance Program $54,385
93.461 Covid-19 Testing for the Uninsured $2,695