Finding 2024-001
significant deficiencyrepeat finding
- Program
- BASIC CENTER GRANT (93.623); CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (21.027)
- Compliance requirement
- Procurement and suspension and debarment
- Repeat
- Chain of 2 audit years; prior finding 2023-003
- FAC record
- FY2024 audit on fac.gov
Finding text from the filing
Federal Agency: U.S. Department of Health and Human Services
Assistance Listing Numbers: 21.027 & 93.623
Federal Program Titles: Coronavirus State and Local Fiscal Recovery Funds; Basic Center Grant
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318, General procurement standards, requires that non-Federal entities must have documented procurement procedures, consistent with State and local laws and regulations for the acquisition of property or services required under a federal award and subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.326.
Condition: During our testing, we noted that the Organization’s procurement policy did not address all of the identified requirements in 2 CFR 200.318 through 200.326.
Questioned Costs: None.
Context: In our review of the current procurement policy, [the auditor] noted the following: • The policy did not include documented procedures for purchases above the simplified acquisition threshold ($250,000) in accordance with 2 CFR 200.320b. • The policy did not include documented procedures for the use and instances of noncompetitive procurement in accordance with 2 CFR 200.320c. • The policy did not include documented procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded as outlined in 2 CFR sections 200.212 and 200.318. • We also noted that the Organization did not verify that the entities with which it entered into contracts were not debarred, suspended, or otherwise excluded.
Effect: The Organization’s procurement policy is not in compliance with general procurement standards, and proper verification procedures for potentially suspended or debarred entities were not performed.
Repeat Finding: This is a repeat finding.
Recommendation: We recommend that the Organization update their procurement policy to address all requirements identified in 2 CFR 200.318 through 200.326.
Views of Responsible Officials: Management agrees with the finding.