KENNEBEC BEHAVIORAL HEALTHNon-Profit

2022-001 Noncompliance with Procurement, Suspension, & Debarment Standard ? 93.829 Criteria ? 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.320 (a)(2)(i) requires that price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-federal entity for purchases over $50,000. Kennebec Behavioral Health?s internal policy is to obtain bids and document an analysis for all purchases at a lower threshold of $25,001. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred under covered transactions. Condition and Context ? Audit procedures revealed that there was not a competitive bid process before entering into a consulting agreement that was over the Uniform Administrative Requirement?s, as well as the Organization?s thresholds. In addition, there was not a process in place to formally document the review of that contracting entity for suspension and debarment prior to entering into the agreement. Cause ? The Organization does not have a formal form to document bids, suspension, and debarment. The documentation of these processes was left to manager discretion. There were time constraints for budget submission that lead to the manager determining that there was not sufficient time to solicit bids. Though no additional attempts to solicit bids were documented, the manager reported that she relied on recommendations from peer Organizations who had gone through a bidding process for similar contracts. No analysis was formally documented in writing prior to entering into the agreement, though it was clear that the manager thoughtfully considered the Organization?s options and determined that the contractor was the best suited for the agreement. Effect ? The Organization was not in compliance with procurement standards for bids on the consulting agreement tested. The Organization did not formally document its initial review of suspension and debarment for this agreement, though the contractor was found to not be on prohibited lists at annual review. Questioned Costs ? None Recommendations ? Management should strengthen their processes, controls, and review over procurement, suspension, and debarment processes and ensure compliance with Uniform Administrative Requirements, as well as their own procurement policies. Views of Responsible Officials and Planned Corrective Actions ? Senior management has formally reminded and reviewed KBH?s policies for procurement and sanction screening for exclusion/suspension/debarment with the full management team and Business Operations group. To assist with the process, a checklist for large purchases and/or service contracts will be developed and required to be attached to any new purchases and/or contracts. KBH?s Policy 1520, Procurement Bidding Requirements, has been revised to include the checklist requirement. As specifically related to the contract noted above, KBH developed an RFP and reissued solicitations for Evaluator work for CCBHC, effective 10/31/22.