Maverick County Hospital District

Congressional Directives ALN 93.493 U.S. Department of Health and Human Services Award Year: September 1, 2024 to August 31, 2025 Criteria or specific requirement – Procurement, Suspension and Debarment (2 CFR 200.317 – 200.327; 2 CFR 180.220) Condition – The District is required to have procedures to ensure vendors are not suspended or debarred prior to charging services to the grant, as well as required to follow their own documented procurement procedures which should conform to the Uniform Guidance procurement standards. Cause – The District did not follow compliant procurement procedures prior to charging services to the grant. Effect or potential effect – The District’s procurement policy does not include required suspension and debarment procedures. In addition, the District did not provide for full and open competition in procuring services with grant funds. Questioned costs – $312,535 – Questioned costs represent expenses for the tested vendors in which price or rate quotations from an adequate number of qualified sources were not obtained. Context – Out of a population of three vendors with expenses directly charged to the grant that were above the micro-purchase threshold, two contracts were selected for testing. Our sampling method was not and was not meant to be statistically valid. The District did not obtain price or rate quotations from an adequate number of qualified sources for either of the vendors selected for testing. Identification as a repeat finding – N/A Recommendation – Contracts directly charged to a federal award should be reviewed to ensure compliance with the Uniform Guidance. Views of responsible officials and planned corrective actions – The District has reviewed the applicable requirements of the Office of Management and Budget Uniform Guidance for procurement standards, specifically those related to the requirement for procedures to be documented regarding suspension and debarment and noncompetitive procurement. The District acknowledges that their procurement policy does not currently conform to the Uniform Guidance procurement standards, and formal procurement methods were not utilized for certain grant expenses. At the time of procurement, the District operated under the understanding that engagement of a vendor holding a General Services Administration (GSA) contract was consistent with and would satisfy applicable procurement requirements. Upon further review, the District recognizes that this assumption did not, in itself, meet all Uniform Guidance requirements, particularly with respect to documentation and justification of procurement methods. To ensure compliance with Uniform Guidance going forward, the District will implement corrective actions. The District will update the current procurement policy to ensure compliance with the Uniform Guidance. The District will provide formal training to existing grant Program Managers on Uniform Guidance procurement standards. Additionally, for any new grant opportunities, the grant committee will receive training on Uniform Guidance procurement standards prior to the completion of grant applications. For both existing and future grants, any proposed contracts or purchases exceeding $3,000 will be subject to review by the grant Program Manager (or the Grant Committee lead, if a Program Manager has not yet been assigned) to ensure that the appropriate procurement method is utilized, all required documentation is obtained and retained, and compliance with all applicable procurement standards is verified prior to purchase or execution of any contract. Responsible Official – Ana Zavala, Chief Financial Officer Planned Corrective Actions – These corrective actions will be implemented immediately, with training completed by May 31, 2026. Criteria or specific requirement – Procurement, Suspension and Debarment (2 CFR 200.317 – 200.327; 2 CFR 180.220)