Dimock Community FoundationNon-Profit

Finding 2025-001 Federal Program: Congressional Directives Assistance Listing Number: 93.493 Compliance Requirement: Procurement Criteria or Specific Requirement: Title 2 CFR §200.318 through §200.326 requires non-Federal entities to use documented procurement procedures that provide for full and open competition and are consistent with applicable Federal standards. Specifically, 2 CFR §200.320 requires procurement transactions for construction in excess of the simplified acquisition threshold to be conducted using competitive proposals or sealed bids, unless conditions exist to justify noncompetitive procurement. Additionally, the Agency’s internal procurement policy requires competitive bidding for construction projects exceeding established dollar thresholds unless an approved exception is documented. Condition: During our audit of procurement transactions charged to the Federal program, we noted that the Agency did not obtain competitive bids for a construction project funded in part with Federal award funds. The project was awarded to a contractor without evidence that competitive proposals were solicited, evaluated, or documented. Furthermore, the Agency did not maintain documentation supporting a noncompetitive procurement justification or evidence of advance written approval as required by Uniform Guidance and internal policy. Cause: The condition appears to have resulted from inadequate internal controls over procurement compliance, including insufficient review of procurement documentation prior to contract execution and limited understanding of Uniform Guidance procurement requirements by personnel responsible for project oversight. Additionally, there has been turnover in senior leadership positions since receipt of the award and since the project began. Effect and Questioned Costs: The failure to follow Uniform Guidance procurement requirements increases the risk that Federal funds may not be used in a manner that ensures full and open competition, reasonableness of cost, and compliance with federal regulations. This condition exposes the Agency to potential disallowance of costs, repayment of federal funds, and increased scrutiny from the Federal awarding agency or pass-through entity. No questioned costs were identified as a result of this finding. Was the finding a repeat of a finding in the immediately prior year? No Recommendation: We recommend that the Agency strengthen internal controls over procurement by: 1. Ensuring all construction procurements funded by Federal awards comply with the competitive procurement requirements of 2 CFR Part 200. 2. Requiring documented evidence of bid solicitation, evaluation, and selection prior to contract award. 3. Establishing procedures to ensure noncompetitive procurements are supported by written justification and receive required approvals in advance. 4. Providing periodic training to personnel involved in procurement and project management on Uniform Guidance requirements. Management Response: The procurement of construction services funded through this award was done in early 2023 and preceded Dimock’s updated procurement policy which calls for competitive bidding. It also preceded changes in procurement leadership. Subsequent procurement for services have since been subject to competitive bidding by Dimock consistent with CFR 200.318-200.326.

Finding 2024-001: Health Center Program Uniform Data System (UDS) Report This finding impacts the reporting compliance requirement for the major program, Assistance Listing Number 93.224/93.527 Health Center Program Cluster. Criteria: Health Center Program grant recipients are required to file a UDS report that provides standardized information about the performance and operation of health centers delivering health care services to underserved communities and vulnerable populations. The UDS report is due 45 days after the calendar year end for the initial submission, and 90 days after calendar year end for the final submission to the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services Condition: The UDS report final submission was due on March 31, 2024; however, it was not submitted until April 18, 2024. Cause: There was oversight in tracking the submission due dates. Effect: The Agency was not in compliance with the reporting requirements of the Health Center Program grant. Recommendation: We recommend that the Agency enhance controls and monitoring procedures over Federal grant requirements to ensure future reports are submitted on time. Management Response: In 2024, the UDS submission was led by our Chief Information Officer with support from a Financial Analyst. In prior years, the submission was headed by the Director of Finance who had been with the organization for 10+ years. She left in November of 2023 and as a result the organization lost some institutional knowledge and UDS experience. In 2025, the 2024 UDS submission was managed by the Chief Financial Officer and submitted by February 15th, 2025. All follow-up requests from the reviewer were resolved prior to March 31, 2025. We don’t foresee any further issues with future submissions.