March of Dimes Inc

Criteria: In accordance with Title 2 CFR Part 200.318, the Organization must maintain records to document the history of procurement of a vendor. Records include, but are not limited to, rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: For two (2) procurements made during fiscal year 2023, approval of the competitive bid analysis was not documented, and the analysis was not maintained with the related purchase order/vendor agreement. For a separate procurement during fiscal year 2023, the suspension and debarment check performed prior to execution of the agreement was not maintained or documented with the related purchase order/vendor agreement. Cause: Documentation supporting the procurement of contractors was not maintained in a logical manner to document the history of procurement. This finding was originally identified as part of the 2022 audit (2022-002) and reoccurred during 2023. Effect: Without appropriate documentation, the Organization may be unable to support whether the procurement of the vendors was performed in accordance with the procurement standards noted in Title 2 CFR Part 200.318. Questioned Costs: N/A Recommendation: Management should develop formal approval and record retention policies as it relates to the documentation pertaining to activities funded by federal awards. Views of Responsible Officials: Refer to Corrective Action Plan.

Management agrees with the auditors’ comments, and the March of Dimes (MOD) has taken the following steps to strengthen the related internal controls. Due to transitions in personnel and decentralized filing systems the supporting documentation for the competitive bid process/sole source justification related to two procurement transactions and the suspension and debarment check related to one procurement item were not maintained. To address the document retention concerns MOD stood up Asana, a grant tracking system, during 2023 for project management and implemented a 7-step checklist for grant funded procurement that includes a centralized housing location for documentation. Asana and the complementary process were fully implemented in October 2023 with compliance overseen by the Office of Sponsored Projects (OSP) with regular support, guidance, and periodic validation from the Finance Office through weekly meetings with the Director of Grants Accounting. To further expand MOD staff knowledge and expertise regarding federal grant management, by the end of October 2023, all key finance and program personnel using grant funds for salary or other expenses and/or fulfilling grant goals and deliverables received a certificate for completing the Center for Disease Control Foundation’s Federal Grants Management training. By December 2024, MOD will host a virtual Federal Grant Management staff training for all key finance and program personnel that use federal grant funds. This training will include the recent revisions to 2 CFR 200. Beginning in January 2024, MOD also implemented grant on-boarding for staff using grant funds as new grant awards are received.

2022-002

Finding 2022-002 U.S. Department of Health and Human Services 93.421 ? Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation?s Health Procurement (Significant Deficiency) Criteria: In accordance with Title 2 CFR Part 200.318, the Organization must maintain records to document the history of procurement of a contractor. Records include, but are not limited to, rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: For 2 procurements made during fiscal year 2022, the competitive bid documentation did not include evidence of review or approval by a department/market supervisor or the procurement team. Further, such documentation was not maintained with the signed contractor agreement. Cause: Documentation supporting the procurement of contractors was not maintained in a logical manner to document the history of procurement. Effect: Without appropriate documentation, the Organization may be unable to support whether the procurement of the contractors was performed in accordance with the procurement standards noted in Title 2 CFR Part 200.318. Recommendation: Management should develop an approval policy for competitive bids documentation as well as a records retention policy for procurement decisions made that includes the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Vendor files should be stored in a centralized location within the Organization. Management should also perform a periodic review of contractor files to ensure such documentation is maintained. Views of Responsible Officials: Although sole source and competitive bid information were obtained, they were not located in a centralized location and the written supporting approvals were not maintained. By the end of October 2023, Management will update, enforce, and retrain team members on procurement policies to include competitive bid documentation and record retention requirements. The required supporting documentation will also be housed in a centralized location and Management will perform periodic reviews to ensure it is properly maintained. To further expand training, by the end of October 2023, all key finance and program personnel will also complete Federal Grants Management training offered by the CDC Foundation.

Although sole source and competitive bid information were obtained, they were not located in a centralized location and the written supporting approvals were not maintained. By the end of October 2023, Management will update, enforce, and retrain team members on procurement policies to include competitive bid documentation and record retention requirements. The required supporting documentation will also be housed in a centralized location and Management will perform periodic reviews to ensure it is properly maintained. To further expand training, by the end of October 2023, all key finance and program personnel will also complete Federal Grants Management training offered by the CDC Foundation.