MHP SALUDNon-Profit

2019-001 ? Procurement Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Sponsor Award Number: 529-17-0046-00001 Sponsor Agency: Texas Health and Human Services Commission Criteria: The final regulations of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (?UG?) made substantial changes to the cost principles related to procurement effective for the June 30, 2019 year. Under the UG, there are several new methods that must be followed: ? Micro purchases, which apply to goods and services less than $10,000, do not require competitive quotes but does require attempts at equitable distribution to avoid all purchases from the same vendor. ? Small purchases, which apply to goods and services directly charged to federal awards that are more than $10,000 but below the Simplified Acquisition Threshold ($250,000), require multiple rate quotes from qualified sources. ? Sealed bids when services are above the $250,000 level and which are most applicable for construction. ? Competitive proposals to be used when sealed bids are not practical. There are 5 standards that an organization must comply with regardless of which procurement method is used: ? Written procedures, ? Expenses must be necessary and reasonable, ? Subject to open competition, ? Code of conduct and conflict of interest policies must be adhered to, and ? Contain proper documentation including the detail of the purchase transaction, support of the procurement method used and the basis of the award and price. Citation: 2 CFR 200.320 Condition: The Organization?s procurement policy did not contain the criteria outlined in the regulation. Cause: The Organization did not update the procurement policy to be in line with the new requirements under Uniform Guidance. Effect: There is a risk that purchases will be made that do not contain the proper bids or be documented in a manner that is consistent with federal guidelines. Questioned Costs: None. Context: The policy did not contain all the criteria for procurement thresholds above the micro purchase level. Repeat Finding: No Recommendation: We recommend that management make changes to the current policy to be consistent with the federal requirements.