Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-001 Special Tests and Provisions Identification of the Federal Program: Grantor: Department of Education Program Name: Federal Direct Student Loans Assistance Listing No.: 84.268 Criteria or Specific Requirement: N7. Direct Loan Reconciliation ? Institutions must report all loan disbursements and submit required records to the Common Origination Disbursement system (COD) within 15 days of disbursement (OMB No. 1845-0021). Each month, COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records. Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: The School did not complete or maintain a record of the required monthly reconciliations during the year ended December 31, 2022. Cause: The School?s policies and control framework did not address the performance of the monthly reconciliations. Effect or Potential Effect: The lack of an effective control in place to complete these reconciliations could result in the misreporting of information in COD. The School does complete timely cash reconciliations, which mitigates the likelihood of questioned costs. Questioned Costs: None identified Context: In a sample of 4 monthly reconciliations, all were found to be noncompliant with the required procedures. Recommendation: Management should update its policies to establish procedures for completing the monthly reconciliation to COD. Management should establish adequate controls to review and approve the reconciliation on a monthly basis in accordance with the compliance requirements. Views of Responsible Officials: Management agrees with the finding described above. The School?s Office of Student Financial Services has implemented a combined monthly reconciliation and drawdown process that identifies and resolves discrepancies, as required by the U.S. Department of Education?s Direct Loan reconciliation guidelines under 34 CFR 685.300(b)(5). The process will be detailed in the School?s procedure manual and staff will be trained accordingly. With this new process in place, we will be compliant with the U.S. Department of Education regulations.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-001 Special Tests and Provisions Identification of the Federal Program: Grantor: Department of Education Program Name: Federal Direct Student Loans Assistance Listing No.: 84.268 Criteria or Specific Requirement: N7. Direct Loan Reconciliation ? Institutions must report all loan disbursements and submit required records to the Common Origination Disbursement system (COD) within 15 days of disbursement (OMB No. 1845-0021). Each month, COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records. Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: The School did not complete or maintain a record of the required monthly reconciliations during the year ended December 31, 2022. Cause: The School?s policies and control framework did not address the performance of the monthly reconciliations. Effect or Potential Effect: The lack of an effective control in place to complete these reconciliations could result in the misreporting of information in COD. The School does complete timely cash reconciliations, which mitigates the likelihood of questioned costs. Questioned Costs: None identified Context: In a sample of 4 monthly reconciliations, all were found to be noncompliant with the required procedures. Recommendation: Management should update its policies to establish procedures for completing the monthly reconciliation to COD. Management should establish adequate controls to review and approve the reconciliation on a monthly basis in accordance with the compliance requirements. Views of Responsible Officials: Management agrees with the finding described above. The School?s Office of Student Financial Services has implemented a combined monthly reconciliation and drawdown process that identifies and resolves discrepancies, as required by the U.S. Department of Education?s Direct Loan reconciliation guidelines under 34 CFR 685.300(b)(5). The process will be detailed in the School?s procedure manual and staff will be trained accordingly. With this new process in place, we will be compliant with the U.S. Department of Education regulations.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.