March of Dimes IncNon-Profit

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.

Finding 2022-001 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 Cash Management (Significant Deficiency) Criteria: Per the Organization?s policy for submitting requests to the Centers for Disease Control (CDC) for reimbursement, and in accordance with Title 2 CFR Part 200.303, the Organization requires review and approval of such requests before they are processed through the CDC?s payment management system. Condition: For one reimbursement request made with the CDC, approval of the request was not documented. Cause: There was not adequate tracking of approval documentation with the cash management records. Effect: The Organization is unable to support whether the Organization?s policy for reimbursement requests was followed and whether approval occurred prior to the request was processed within the CDC payment management system. Questioned Costs: N/A Recommendation: We recommend that the Organization strengthen internal controls surrounding the cash management process to ensure appropriate documentation of the cash management review and approval workflow is maintained. Views of Responsible Officials: Due to transitions in personnel and systems, written support for the approval of a request for reimbursement was not available. A new Director of Grants Accounting was hired in August 2023 and has reviewed and been trained on the cash management policy. Effective October 2023, written supporting documentation of the review and approval of requests for reimbursement will be obtained and maintained by Grant Accounting staff, in accordance with March of Dimes policy and federal cash management requirements.

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.

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