219 Health Network, Inc.Non-Profit

Information on the Federal Program Federal Program Name: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services Federal Assistance Listing Title and Number: Affordable Care Act (ACA) Grants for New and Expanded Services Under the Health Center Program, 93.527 Criteria or Specific Requirement: Under Uniform Guidance compliance requirements for Procurement (2 CFR 200.320 (a) (1) (ii)), 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 it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. Also, the Uniform Guidance compliance requirements for Procurement (Appendix II to Part 200), require that Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain provisions enumerated in Appendix II to Part 200 (A) to (L). Condition: The Organization entered to various professional services contracts for marketing, advertising and information dissemination that do not exceed the simplified acquisition threshold and are considered micro-purchase awards, but did not maintain appropriate documentation to document the price reasonableness based on research, experience, and purchase history to support its procurement decisions. Contracts entered into also do not include the contract provision required by Appendix II to Part 200. Questioned Costs: $0 Context: During our testing of procurement requirements, vendor contracts over the micro-purchase threshold did not have appropriate documentation to evidence the basis of vendor selection (documentation of the price reasonableness based on research, experience, and purchase history). Also, related to the vendor payments, noted that vendor contracts do not contain the provisions enumerated in Appendix II to Part 200 (A) to (L). Effect: Micro-purchases were made without appropriate documentation to comply with Uniform Guidance requirements. Also, contracts were entered into and approved without the required provision of Appendix II to Part 200 of the Uniform Guidance. Cause: The Organization does not have a comprehensive procurement policy that is in line with Uniform Guidance requirements. Adequate supporting documentation on the procurements were not obtained or maintained within vendor files and vendor contracts do not contain the necessary contract provision and language required by the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the Organization revisit controls over this compliance requirement to ensure that appropriate documentation is gathered and retained within its procurement files to support all Federally funded purchasing decisions. We also recommend the Organization perform a comprehensive review of its procurement policy and ensure that it is in compliance and in-line with the procurement requirements of the Uniform Guidance. Views of responsible officials and planned corrective actions: The Organization will develop a policy and checklist to maintain written documentation of vendor selection and procurement process, along with the review and approval process required under the Uniform Guidance requirements.