EIN: 411857830
UEI: KNXTZ2UJD513
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 27, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 27, 2025 (517 days ago).
What is a management decision? →For the one contractor not considered a sole source vendor, PACT obtained three quotes or proposals but did not have documentation supporting the selection of this vendor. In addition, PACT did not collect a certification that the contractor is not suspended or debarred or document its verification that this contractor was not suspended, debarred, or otherwise excluded at SAM.gov before entering into the covered transaction. Questioned Costs: None Context: The majority of costs associated with this federal grant are payroll related with only five vendors providing goods or services that exceeded the micro-purchase threshold ($10,000). Other expenditures incurred are typically not related to contracts. PACT’s policy for non-payroll disbursements requires an approved Expenditure Authorization Form (EAF) as support documenting the reason for the purchase. PACT’s policy does not require documentation supporting the reason for the vendor selection. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing and Single Audits. Effect: It cannot be determined that the contracting process was open and fair because PACT did not document the rationale for the contractor selection. It also cannot be determined that an entity was not suspended, debarred, or otherwise excluded because PACT did not document that it performed a search on SAM.gov and did not collect a certification. Cause: PACT was not aware of the requirement to document the reasoning behind its contractor selections and believed obtaining quotes was sufficient. In addition, PACT believed that performing the search was sufficient and that documentation of the search or collection of a certification was not necessary. Revised procedures were in the process of being implemented during 2023. Recommendation: We recommend PACT develop formal procedures to document why a vendor is selected when price is not the sole factor (i.e., checklist or other criteria developed ahead of time). We recommend that PACT keep printouts (with dates) from SAM.gov to support that contractors were not suspended, debarred, or otherwise excluded prior to entering into covered transactions and collect certifications as required by policy. View of Responsible Official: Acknowledge
Show full finding ▾Hide full finding ▴2023-001 Procurement, Suspension, and Debarment Prior Year Finding Number: N/A Year of Finding Origination: 2023 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Health and Human Services Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) (Journey to Independence) Award Number and Year: 5H79SM082970-03; 2023 and 5H79SM082970-04; 2024 Pass-Through Agency: Direct Award Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. PACT’s procurement policy requires that the contractor submit a certification that they are not suspended and debarred and also requires PACT staff to verify the vendor is not suspended, debarred, or otherwise excluded at SAM.gov. Condition: For the one contractor not considered a sole source vendor, PACT obtained three quotes or proposals but did not have documentation supporting the selection of this vendor. In addition, PACT did not collect a certification that the contractor is not suspended or debarred or document its verification that this contractor was not suspended, debarred, or otherwise excluded at SAM.gov before entering into the covered transaction. Questioned Costs: None Context: The majority of costs associated with this federal grant are payroll related with only five vendors providing goods or services that exceeded the micro-purchase threshold ($10,000). Other expenditures incurred are typically not related to contracts. PACT’s policy for non-payroll disbursements requires an approved Expenditure Authorization Form (EAF) as support documenting the reason for the purchase. PACT’s policy does not require documentation supporting the reason for the vendor selection. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing and Single Audits. Effect: It cannot be determined that the contracting process was open and fair because PACT did not document the rationale for the contractor selection. It also cannot be determined that an entity was not suspended, debarred, or otherwise excluded because PACT did not document that it performed a search on SAM.gov and did not collect a certification. Cause: PACT was not aware of the requirement to document the reasoning behind its contractor selections and believed obtaining quotes was sufficient. In addition, PACT believed that performing the search was sufficient and that documentation of the search or collection of a certification was not necessary. Revised procedures were in the process of being implemented during 2023. Recommendation: We recommend PACT develop formal procedures to document why a vendor is selected when price is not the sole factor (i.e., checklist or other criteria developed ahead of time). We recommend that PACT keep printouts (with dates) from SAM.gov to support that contractors were not suspended, debarred, or otherwise excluded prior to entering into covered transactions and collect certifications as required by policy. View of Responsible Official: Acknowledge
Finding Number: 2023-001 Finding Title: Procurement, Suspension and Debarment Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) (Journey to Independence) Name of Contact Person Responsible for Corrective Action: Jolene Lambert, Finance and Benefits Coordinator Corrective Action Planned: To ensure consistency in managing sponsored projects, PACT for Families Collaborative implemented a procurement policy effective June 25, 2024, per Uniform Guidance Procurement Standards. In October 2023, we transitioned to an updated expenditure authorization process that includes a revised Expenditure Authorization Form (EAF) that requires pricing from multiple suppliers to document and secure the most reasonable purchase. While suspensions and debarments have been checked through SAM.gov for several years, printouts of the verification process were not retained. As of August 29, 2023, printouts are now kept as official documentation. The one micro-purchase identified during the audit occurred before this date. Anticipated Completion Date: August 29, 2023
FAC accepted this audit on January 22, 2024 — management decision was due July 22, 2024.
In a sample of eight micro-purchase disbursements tested, none had written documentation supporting why the vendors were selected, and that prices were reasonable. Questioned Costs: None. Context: The majority of costs associated with this federal grant are payroll related. PACT’s policy for non-payroll disbursements requires an approved Expenditure Authorization Form (EAF) as documentation supporting the reason for the purchase. PACT’s policy does not require documentation supporting the reason why the vendor was selected or that the price is reasonable for micro-purchase transactions. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: By not documenting why vendors were selected for micro-purchase transactions, it cannot be determined that purchases were distributed equitably among qualified suppliers or that prices were reasonable. Cause: Client relied on the approval process and allowability of transactions as to why purchases were made. PACT is aware that multiple vendors need to be considered when practicable but was unaware that it needed to be formally documented. Recommendation: We recommend that PACT implement additional procedures to document why a vendor is selected and if the price is reasonable for every micro-purchase transaction. View of Responsible Official: Acknowledge.
Show full finding ▾Hide full finding ▴2022-001 Micro-Purchasing Documentation Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Health and Human Services Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) (Journey to Independence) Award Number and Year: 6H79SM082970-02M001; 2022 and 5H79SM082970-03; 2023 Pass-Through Agency: Direct Award Criteria: Title 2 U.S. Code of Federal Regulations §§ 200.320(a)(1)(i & ii) state to the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history, or other information and documents its files accordingly. Condition: In a sample of eight micro-purchase disbursements tested, none had written documentation supporting why the vendors were selected, and that prices were reasonable. Questioned Costs: None. Context: The majority of costs associated with this federal grant are payroll related. PACT’s policy for non-payroll disbursements requires an approved Expenditure Authorization Form (EAF) as documentation supporting the reason for the purchase. PACT’s policy does not require documentation supporting the reason why the vendor was selected or that the price is reasonable for micro-purchase transactions. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: By not documenting why vendors were selected for micro-purchase transactions, it cannot be determined that purchases were distributed equitably among qualified suppliers or that prices were reasonable. Cause: Client relied on the approval process and allowability of transactions as to why purchases were made. PACT is aware that multiple vendors need to be considered when practicable but was unaware that it needed to be formally documented. Recommendation: We recommend that PACT implement additional procedures to document why a vendor is selected and if the price is reasonable for every micro-purchase transaction. View of Responsible Official: Acknowledge.
Finding Number: 2022-001 Finding Title: Micro-Purchasing Documentation Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (Journey to Independence) Name of Contact Person Responsible for Corrective Action: Jolene Lambert, Finance and Benefits Coordinator Corrective Action Planned: To keep policies for managing sponsored projects consistent, PACT for Families Collaborative will ensure Uniform Guidance Procurement Standards for all sponsored projects. We will use an updated expenditure authorization process to assure micro-purchases are distributed equitably among qualified suppliers by updating our EAF (Expenditure Authorization Form) to include a process to assure more than one supplier is priced and documented for the most reasonable purchase. Anticipated Completion Date: Ending December 31, 2023
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