Audit 28674

FY End
2022-12-31
Total Expended
$679.00M
Findings
840
Programs
89
Year: 2022 Accepted: 2023-09-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
20201 2022-002 Material Weakness - I
20202 2022-002 Material Weakness - I
20203 2022-002 Material Weakness - I
20204 2022-002 Material Weakness - I
20205 2022-002 Material Weakness - I
20206 2022-002 Material Weakness - I
20207 2022-002 Material Weakness - I
20208 2022-002 Material Weakness - I
20209 2022-002 Material Weakness - I
20210 2022-002 Material Weakness - I
20211 2022-002 Material Weakness - I
20212 2022-002 Material Weakness - I
20324 2022-002 Material Weakness - I
20325 2022-002 Material Weakness - I
20326 2022-002 Material Weakness - I
20327 2022-002 Material Weakness - I
20328 2022-002 Material Weakness - I
20329 2022-002 Material Weakness - I
20330 2022-002 Material Weakness - I
20331 2022-002 Material Weakness - I
20332 2022-002 Material Weakness - I
20333 2022-002 Material Weakness - I
20334 2022-002 Material Weakness - I
20335 2022-002 Material Weakness - I
20336 2022-002 Material Weakness - I
20337 2022-002 Material Weakness - I
20338 2022-002 Material Weakness - I
20339 2022-002 Material Weakness - I
20340 2022-002 Material Weakness - I
20341 2022-002 Material Weakness - I
20342 2022-002 Material Weakness - I
20343 2022-002 Material Weakness - I
20344 2022-002 Material Weakness - I
20345 2022-002 Material Weakness - I
20346 2022-002 Material Weakness - I
20347 2022-002 Material Weakness - I
20348 2022-002 Material Weakness - I
20349 2022-002 Material Weakness - I
20350 2022-002 Material Weakness - I
20351 2022-002 Material Weakness - I
20352 2022-002 Material Weakness - I
20353 2022-002 Material Weakness - I
20354 2022-002 Material Weakness - I
20355 2022-002 Material Weakness - I
20356 2022-002 Material Weakness - I
20357 2022-002 Material Weakness - I
20358 2022-002 Material Weakness - I
20481 2022-002 Material Weakness - I
20482 2022-002 Material Weakness - I
20483 2022-002 Material Weakness - I
20484 2022-002 Material Weakness - I
20485 2022-002 Material Weakness - I
20486 2022-002 Material Weakness - I
20487 2022-002 Material Weakness - I
20488 2022-002 Material Weakness - I
20489 2022-002 Material Weakness - I
20490 2022-002 Material Weakness - I
20491 2022-002 Material Weakness - I
20492 2022-002 Material Weakness - I
20493 2022-002 Material Weakness - I
20494 2022-002 Material Weakness - I
20495 2022-002 Material Weakness - I
20496 2022-002 Material Weakness - I
20497 2022-002 Material Weakness - I
20498 2022-002 Material Weakness - I
20499 2022-002 Material Weakness - I
20500 2022-002 Material Weakness - I
20501 2022-002 Material Weakness - I
20502 2022-002 Material Weakness - I
20503 2022-002 Material Weakness - I
20504 2022-002 Material Weakness - I
20505 2022-002 Material Weakness - I
20506 2022-002 Material Weakness - I
20507 2022-002 Material Weakness - I
20567 2022-002 Material Weakness - I
20568 2022-002 Material Weakness - I
20569 2022-001 Material Weakness - N
20570 2022-002 Material Weakness - I
20571 2022-002 Material Weakness - I
20572 2022-002 Material Weakness - I
20573 2022-002 Material Weakness - I
20574 2022-002 Material Weakness - I
20575 2022-002 Material Weakness - I
20576 2022-002 Material Weakness - I
20577 2022-002 Material Weakness - I
20578 2022-002 Material Weakness - I
20579 2022-002 Material Weakness - I
20580 2022-002 Material Weakness - I
20581 2022-002 Material Weakness - I
20582 2022-002 Material Weakness - I
20646 2022-002 Material Weakness - I
20647 2022-002 Material Weakness - I
20648 2022-002 Material Weakness - I
20649 2022-002 Material Weakness - I
20650 2022-002 Material Weakness - I
20651 2022-002 Material Weakness - I
20652 2022-002 Material Weakness - I
20653 2022-002 Material Weakness - I
20654 2022-002 Material Weakness - I
20655 2022-002 Material Weakness - I
20656 2022-002 Material Weakness - I
20657 2022-002 Material Weakness - I
20785 2022-002 Material Weakness - I
20786 2022-002 Material Weakness - I
20787 2022-002 Material Weakness - I
20788 2022-002 Material Weakness - I
20789 2022-002 Material Weakness - I
20790 2022-002 Material Weakness - I
20791 2022-002 Material Weakness - I
20792 2022-002 Material Weakness - I
20793 2022-002 Material Weakness - I
20794 2022-002 Material Weakness - I
20795 2022-002 Material Weakness - I
20796 2022-002 Material Weakness - I
20797 2022-002 Material Weakness - I
20798 2022-002 Material Weakness - I
20799 2022-002 Material Weakness - I
20800 2022-002 Material Weakness - I
20801 2022-002 Material Weakness - I
20802 2022-002 Material Weakness - I
20803 2022-002 Material Weakness - I
20804 2022-002 Material Weakness - I
20805 2022-002 Material Weakness - I
20806 2022-002 Material Weakness - I
20807 2022-002 Material Weakness - I
21397 2022-002 Material Weakness - I
21398 2022-002 Material Weakness - I
21399 2022-002 Material Weakness - I
21400 2022-002 Material Weakness - I
21401 2022-002 Material Weakness - I
21402 2022-002 Material Weakness - I
21403 2022-002 Material Weakness - I
21404 2022-002 Material Weakness - I
21405 2022-002 Material Weakness - I
21406 2022-002 Material Weakness - I
21407 2022-002 Material Weakness - I
21619 2022-002 Material Weakness - I
21620 2022-002 Material Weakness - I
21621 2022-002 Material Weakness - I
21622 2022-002 Material Weakness - I
21623 2022-002 Material Weakness - I
21624 2022-002 Material Weakness - I
21625 2022-002 Material Weakness - I
21626 2022-002 Material Weakness - I
21650 2022-002 Material Weakness - I
21651 2022-002 Material Weakness - I
21652 2022-002 Material Weakness - I
21653 2022-002 Material Weakness - I
21654 2022-002 Material Weakness - I
21655 2022-002 Material Weakness - I
21656 2022-002 Material Weakness - I
21657 2022-002 Material Weakness - I
21658 2022-002 Material Weakness - I
21659 2022-002 Material Weakness - I
21660 2022-002 Material Weakness - I
21661 2022-002 Material Weakness - I
21662 2022-002 Material Weakness - I
21663 2022-002 Material Weakness - I
21664 2022-002 Material Weakness - I
21665 2022-002 Material Weakness - I
21666 2022-002 Material Weakness - I
21667 2022-002 Material Weakness - I
21668 2022-002 Material Weakness - I
21669 2022-002 Material Weakness - I
21670 2022-002 Material Weakness - I
21671 2022-002 Material Weakness - I
21672 2022-002 Material Weakness - I
21673 2022-002 Material Weakness - I
21674 2022-002 Material Weakness - I
21675 2022-002 Material Weakness - I
21676 2022-002 Material Weakness - I
21677 2022-002 Material Weakness - I
21678 2022-002 Material Weakness - I
21679 2022-002 Material Weakness - I
21680 2022-002 Material Weakness - I
21681 2022-002 Material Weakness - I
21682 2022-002 Material Weakness - I
21683 2022-002 Material Weakness - I
21684 2022-002 Material Weakness - I
21685 2022-002 Material Weakness - I
21686 2022-002 Material Weakness - I
21687 2022-002 Material Weakness - I
21688 2022-002 Material Weakness - I
21689 2022-002 Material Weakness - I
21690 2022-002 Material Weakness - I
21691 2022-002 Material Weakness - I
21692 2022-002 Material Weakness - I
21693 2022-002 Material Weakness - I
21694 2022-002 Material Weakness - I
21695 2022-002 Material Weakness - I
21696 2022-002 Material Weakness - I
21697 2022-002 Material Weakness - I
21698 2022-002 Material Weakness - I
21699 2022-002 Material Weakness - I
21700 2022-002 Material Weakness - I
21701 2022-002 Material Weakness - I
21917 2022-002 Material Weakness - I
21918 2022-002 Material Weakness - I
21919 2022-002 Material Weakness - I
21920 2022-002 Material Weakness - I
21921 2022-002 Material Weakness - I
21922 2022-002 Material Weakness - I
21923 2022-002 Material Weakness - I
21924 2022-002 Material Weakness - I
21925 2022-002 Material Weakness - I
21926 2022-002 Material Weakness - I
25778 2022-002 Material Weakness - I
25844 2022-002 Material Weakness - I
25845 2022-002 Material Weakness - I
25846 2022-002 Material Weakness - I
25847 2022-002 Material Weakness - I
25848 2022-002 Material Weakness - I
25849 2022-002 Material Weakness - I
25850 2022-002 Material Weakness - I
25851 2022-002 Material Weakness - I
25852 2022-002 Material Weakness - I
25853 2022-002 Material Weakness - I
25872 2022-002 Material Weakness - I
25873 2022-002 Material Weakness - I
25874 2022-002 Material Weakness - I
25875 2022-002 Material Weakness - I
25876 2022-002 Material Weakness - I
25877 2022-002 Material Weakness - I
25878 2022-002 Material Weakness - I
25879 2022-002 Material Weakness - I
25880 2022-002 Material Weakness - I
25881 2022-002 Material Weakness - I
25882 2022-002 Material Weakness - I
25883 2022-002 Material Weakness - I
25884 2022-002 Material Weakness - I
25885 2022-002 Material Weakness - I
25886 2022-002 Material Weakness - I
25887 2022-002 Material Weakness - I
25888 2022-002 Material Weakness - I
25889 2022-002 Material Weakness - I
25890 2022-002 Material Weakness - I
25891 2022-002 Material Weakness - I
25892 2022-002 Material Weakness - I
25893 2022-002 Material Weakness - I
25894 2022-002 Material Weakness - I
25895 2022-002 Material Weakness - I
25896 2022-002 Material Weakness - I
25897 2022-002 Material Weakness - I
25898 2022-002 Material Weakness - I
25899 2022-002 Material Weakness - I
25900 2022-002 Material Weakness - I
25901 2022-002 Material Weakness - I
25902 2022-002 Material Weakness - I
25903 2022-002 Material Weakness - I
25904 2022-002 Material Weakness - I
25905 2022-002 Material Weakness - I
25906 2022-002 Material Weakness - I
25907 2022-002 Material Weakness - I
25908 2022-002 Material Weakness - I
25909 2022-002 Material Weakness - I
25910 2022-002 Material Weakness - I
25911 2022-002 Material Weakness - I
25912 2022-002 Material Weakness - I
25913 2022-002 Material Weakness - I
25914 2022-002 Material Weakness - I
25915 2022-002 Material Weakness - I
25916 2022-002 Material Weakness - I
25917 2022-002 Material Weakness - I
25918 2022-002 Material Weakness - I
25919 2022-002 Material Weakness - I
25920 2022-002 Material Weakness - I
25921 2022-002 Material Weakness - I
25922 2022-002 Material Weakness - I
25923 2022-002 Material Weakness - I
25924 2022-002 Material Weakness - I
25925 2022-002 Material Weakness - I
25926 2022-002 Material Weakness - I
25927 2022-002 Material Weakness - I
25928 2022-002 Material Weakness - I
25973 2022-002 Material Weakness - I
25974 2022-002 Material Weakness - I
25975 2022-002 Material Weakness - I
25976 2022-002 Material Weakness - I
25977 2022-002 Material Weakness - I
25978 2022-002 Material Weakness - I
25979 2022-002 Material Weakness - I
25980 2022-002 Material Weakness - I
25981 2022-002 Material Weakness - I
25982 2022-002 Material Weakness - I
25983 2022-002 Material Weakness - I
25984 2022-002 Material Weakness - I
25985 2022-002 Material Weakness - I
25986 2022-002 Material Weakness - I
25987 2022-002 Material Weakness - I
25988 2022-002 Material Weakness - I
25989 2022-002 Material Weakness - I
25990 2022-002 Material Weakness - I
25991 2022-002 Material Weakness - I
25992 2022-002 Material Weakness - I
25993 2022-002 Material Weakness - I
25994 2022-002 Material Weakness - I
25995 2022-002 Material Weakness - I
25996 2022-002 Material Weakness - I
25997 2022-002 Material Weakness - I
25998 2022-002 Material Weakness - I
25999 2022-002 Material Weakness - I
26000 2022-002 Material Weakness - I
26001 2022-002 Material Weakness - I
26002 2022-002 Material Weakness - I
26003 2022-002 Material Weakness - I
26039 2022-002 Material Weakness - I
26040 2022-002 Material Weakness - I
26041 2022-002 Material Weakness - I
26042 2022-002 Material Weakness - I
26043 2022-002 Material Weakness - I
26044 2022-002 Material Weakness - I
26045 2022-002 Material Weakness - I
26046 2022-002 Material Weakness - I
26047 2022-002 Material Weakness - I
26048 2022-002 Material Weakness - I
26049 2022-002 Material Weakness - I
26050 2022-002 Material Weakness - I
26051 2022-002 Material Weakness - I
26052 2022-002 Material Weakness - I
26053 2022-002 Material Weakness - I
26054 2022-002 Material Weakness - I
26055 2022-002 Material Weakness - I
26056 2022-002 Material Weakness - I
26057 2022-002 Material Weakness - I
26058 2022-002 Material Weakness - I
26059 2022-002 Material Weakness - I
26060 2022-002 Material Weakness - I
26061 2022-002 Material Weakness - I
26062 2022-002 Material Weakness - I
26063 2022-002 Material Weakness - I
26064 2022-002 Material Weakness - I
26065 2022-002 Material Weakness - I
26066 2022-002 Material Weakness - I
26067 2022-002 Material Weakness - I
26068 2022-002 Material Weakness - I
26069 2022-002 Material Weakness - I
26070 2022-002 Material Weakness - I
26071 2022-002 Material Weakness - I
26072 2022-002 Material Weakness - I
26073 2022-002 Material Weakness - I
26074 2022-002 Material Weakness - I
26133 2022-002 Material Weakness - I
26134 2022-002 Material Weakness - I
26135 2022-002 Material Weakness - I
26136 2022-002 Material Weakness - I
26137 2022-002 Material Weakness - I
26138 2022-002 Material Weakness - I
26139 2022-002 Material Weakness - I
26140 2022-002 Material Weakness - I
26141 2022-002 Material Weakness - I
26142 2022-002 Material Weakness - I
26143 2022-002 Material Weakness - I
26144 2022-002 Material Weakness - I
26145 2022-002 Material Weakness - I
26146 2022-002 Material Weakness - I
26147 2022-002 Material Weakness - I
26148 2022-002 Material Weakness - I
26149 2022-002 Material Weakness - I
26204 2022-002 Material Weakness - I
26205 2022-002 Material Weakness - I
26206 2022-002 Material Weakness - I
26207 2022-002 Material Weakness - I
26208 2022-002 Material Weakness - I
26209 2022-002 Material Weakness - I
26210 2022-002 Material Weakness - I
26211 2022-002 Material Weakness - I
26212 2022-002 Material Weakness - I
26213 2022-002 Material Weakness - I
26214 2022-002 Material Weakness - I
26215 2022-002 Material Weakness - I
26216 2022-002 Material Weakness - I
26217 2022-002 Material Weakness - I
26218 2022-002 Material Weakness - I
26219 2022-002 Material Weakness - I
26220 2022-002 Material Weakness - I
26221 2022-002 Material Weakness - I
26222 2022-002 Material Weakness - I
26223 2022-002 Material Weakness - I
26224 2022-002 Material Weakness - I
26369 2022-002 Material Weakness - I
26370 2022-002 Material Weakness - I
26371 2022-002 Material Weakness - I
27991 2022-002 Material Weakness - I
27992 2022-002 Material Weakness - I
27993 2022-002 Material Weakness - I
27994 2022-002 Material Weakness - I
27995 2022-002 Material Weakness - I
27996 2022-002 Material Weakness - I
27997 2022-002 Material Weakness - I
27998 2022-002 Material Weakness - I
27999 2022-002 Material Weakness - I
28000 2022-002 Material Weakness - I
28001 2022-002 Material Weakness - I
28002 2022-002 Material Weakness - I
28003 2022-002 Material Weakness - I
28004 2022-002 Material Weakness - I
28005 2022-002 Material Weakness - I
28006 2022-002 Material Weakness - I
28007 2022-002 Material Weakness - I
28008 2022-002 Material Weakness - I
28009 2022-002 Material Weakness - I
28010 2022-002 Material Weakness - I
28011 2022-002 Material Weakness - I
28012 2022-002 Material Weakness - I
28013 2022-002 Material Weakness - I
28014 2022-002 Material Weakness - I
28015 2022-002 Material Weakness - I
28016 2022-002 Material Weakness - I
28017 2022-002 Material Weakness - I
28018 2022-002 Material Weakness - I
28019 2022-002 Material Weakness - I
28020 2022-002 Material Weakness - I
28021 2022-002 Material Weakness - I
28022 2022-002 Material Weakness - I
28023 2022-002 Material Weakness - I
28024 2022-002 Material Weakness - I
28025 2022-002 Material Weakness - I
28026 2022-002 Material Weakness - I
28027 2022-002 Material Weakness - I
28028 2022-002 Material Weakness - I
596643 2022-002 Material Weakness - I
596644 2022-002 Material Weakness - I
596645 2022-002 Material Weakness - I
596646 2022-002 Material Weakness - I
596647 2022-002 Material Weakness - I
596648 2022-002 Material Weakness - I
596649 2022-002 Material Weakness - I
596650 2022-002 Material Weakness - I
596651 2022-002 Material Weakness - I
596652 2022-002 Material Weakness - I
596653 2022-002 Material Weakness - I
596654 2022-002 Material Weakness - I
596766 2022-002 Material Weakness - I
596767 2022-002 Material Weakness - I
596768 2022-002 Material Weakness - I
596769 2022-002 Material Weakness - I
596770 2022-002 Material Weakness - I
596771 2022-002 Material Weakness - I
596772 2022-002 Material Weakness - I
596773 2022-002 Material Weakness - I
596774 2022-002 Material Weakness - I
596775 2022-002 Material Weakness - I
596776 2022-002 Material Weakness - I
596777 2022-002 Material Weakness - I
596778 2022-002 Material Weakness - I
596779 2022-002 Material Weakness - I
596780 2022-002 Material Weakness - I
596781 2022-002 Material Weakness - I
596782 2022-002 Material Weakness - I
596783 2022-002 Material Weakness - I
596784 2022-002 Material Weakness - I
596785 2022-002 Material Weakness - I
596786 2022-002 Material Weakness - I
596787 2022-002 Material Weakness - I
596788 2022-002 Material Weakness - I
596789 2022-002 Material Weakness - I
596790 2022-002 Material Weakness - I
596791 2022-002 Material Weakness - I
596792 2022-002 Material Weakness - I
596793 2022-002 Material Weakness - I
596794 2022-002 Material Weakness - I
596795 2022-002 Material Weakness - I
596796 2022-002 Material Weakness - I
596797 2022-002 Material Weakness - I
596798 2022-002 Material Weakness - I
596799 2022-002 Material Weakness - I
596800 2022-002 Material Weakness - I
596923 2022-002 Material Weakness - I
596924 2022-002 Material Weakness - I
596925 2022-002 Material Weakness - I
596926 2022-002 Material Weakness - I
596927 2022-002 Material Weakness - I
596928 2022-002 Material Weakness - I
596929 2022-002 Material Weakness - I
596930 2022-002 Material Weakness - I
596931 2022-002 Material Weakness - I
596932 2022-002 Material Weakness - I
596933 2022-002 Material Weakness - I
596934 2022-002 Material Weakness - I
596935 2022-002 Material Weakness - I
596936 2022-002 Material Weakness - I
596937 2022-002 Material Weakness - I
596938 2022-002 Material Weakness - I
596939 2022-002 Material Weakness - I
596940 2022-002 Material Weakness - I
596941 2022-002 Material Weakness - I
596942 2022-002 Material Weakness - I
596943 2022-002 Material Weakness - I
596944 2022-002 Material Weakness - I
596945 2022-002 Material Weakness - I
596946 2022-002 Material Weakness - I
596947 2022-002 Material Weakness - I
596948 2022-002 Material Weakness - I
596949 2022-002 Material Weakness - I
597009 2022-002 Material Weakness - I
597010 2022-002 Material Weakness - I
597011 2022-001 Material Weakness - N
597012 2022-002 Material Weakness - I
597013 2022-002 Material Weakness - I
597014 2022-002 Material Weakness - I
597015 2022-002 Material Weakness - I
597016 2022-002 Material Weakness - I
597017 2022-002 Material Weakness - I
597018 2022-002 Material Weakness - I
597019 2022-002 Material Weakness - I
597020 2022-002 Material Weakness - I
597021 2022-002 Material Weakness - I
597022 2022-002 Material Weakness - I
597023 2022-002 Material Weakness - I
597024 2022-002 Material Weakness - I
597088 2022-002 Material Weakness - I
597089 2022-002 Material Weakness - I
597090 2022-002 Material Weakness - I
597091 2022-002 Material Weakness - I
597092 2022-002 Material Weakness - I
597093 2022-002 Material Weakness - I
597094 2022-002 Material Weakness - I
597095 2022-002 Material Weakness - I
597096 2022-002 Material Weakness - I
597097 2022-002 Material Weakness - I
597098 2022-002 Material Weakness - I
597099 2022-002 Material Weakness - I
597227 2022-002 Material Weakness - I
597228 2022-002 Material Weakness - I
597229 2022-002 Material Weakness - I
597230 2022-002 Material Weakness - I
597231 2022-002 Material Weakness - I
597232 2022-002 Material Weakness - I
597233 2022-002 Material Weakness - I
597234 2022-002 Material Weakness - I
597235 2022-002 Material Weakness - I
597236 2022-002 Material Weakness - I
597237 2022-002 Material Weakness - I
597238 2022-002 Material Weakness - I
597239 2022-002 Material Weakness - I
597240 2022-002 Material Weakness - I
597241 2022-002 Material Weakness - I
597242 2022-002 Material Weakness - I
597243 2022-002 Material Weakness - I
597244 2022-002 Material Weakness - I
597245 2022-002 Material Weakness - I
597246 2022-002 Material Weakness - I
597247 2022-002 Material Weakness - I
597248 2022-002 Material Weakness - I
597249 2022-002 Material Weakness - I
597839 2022-002 Material Weakness - I
597840 2022-002 Material Weakness - I
597841 2022-002 Material Weakness - I
597842 2022-002 Material Weakness - I
597843 2022-002 Material Weakness - I
597844 2022-002 Material Weakness - I
597845 2022-002 Material Weakness - I
597846 2022-002 Material Weakness - I
597847 2022-002 Material Weakness - I
597848 2022-002 Material Weakness - I
597849 2022-002 Material Weakness - I
598061 2022-002 Material Weakness - I
598062 2022-002 Material Weakness - I
598063 2022-002 Material Weakness - I
598064 2022-002 Material Weakness - I
598065 2022-002 Material Weakness - I
598066 2022-002 Material Weakness - I
598067 2022-002 Material Weakness - I
598068 2022-002 Material Weakness - I
598092 2022-002 Material Weakness - I
598093 2022-002 Material Weakness - I
598094 2022-002 Material Weakness - I
598095 2022-002 Material Weakness - I
598096 2022-002 Material Weakness - I
598097 2022-002 Material Weakness - I
598098 2022-002 Material Weakness - I
598099 2022-002 Material Weakness - I
598100 2022-002 Material Weakness - I
598101 2022-002 Material Weakness - I
598102 2022-002 Material Weakness - I
598103 2022-002 Material Weakness - I
598104 2022-002 Material Weakness - I
598105 2022-002 Material Weakness - I
598106 2022-002 Material Weakness - I
598107 2022-002 Material Weakness - I
598108 2022-002 Material Weakness - I
598109 2022-002 Material Weakness - I
598110 2022-002 Material Weakness - I
598111 2022-002 Material Weakness - I
598112 2022-002 Material Weakness - I
598113 2022-002 Material Weakness - I
598114 2022-002 Material Weakness - I
598115 2022-002 Material Weakness - I
598116 2022-002 Material Weakness - I
598117 2022-002 Material Weakness - I
598118 2022-002 Material Weakness - I
598119 2022-002 Material Weakness - I
598120 2022-002 Material Weakness - I
598121 2022-002 Material Weakness - I
598122 2022-002 Material Weakness - I
598123 2022-002 Material Weakness - I
598124 2022-002 Material Weakness - I
598125 2022-002 Material Weakness - I
598126 2022-002 Material Weakness - I
598127 2022-002 Material Weakness - I
598128 2022-002 Material Weakness - I
598129 2022-002 Material Weakness - I
598130 2022-002 Material Weakness - I
598131 2022-002 Material Weakness - I
598132 2022-002 Material Weakness - I
598133 2022-002 Material Weakness - I
598134 2022-002 Material Weakness - I
598135 2022-002 Material Weakness - I
598136 2022-002 Material Weakness - I
598137 2022-002 Material Weakness - I
598138 2022-002 Material Weakness - I
598139 2022-002 Material Weakness - I
598140 2022-002 Material Weakness - I
598141 2022-002 Material Weakness - I
598142 2022-002 Material Weakness - I
598143 2022-002 Material Weakness - I
598359 2022-002 Material Weakness - I
598360 2022-002 Material Weakness - I
598361 2022-002 Material Weakness - I
598362 2022-002 Material Weakness - I
598363 2022-002 Material Weakness - I
598364 2022-002 Material Weakness - I
598365 2022-002 Material Weakness - I
598366 2022-002 Material Weakness - I
598367 2022-002 Material Weakness - I
598368 2022-002 Material Weakness - I
602220 2022-002 Material Weakness - I
602286 2022-002 Material Weakness - I
602287 2022-002 Material Weakness - I
602288 2022-002 Material Weakness - I
602289 2022-002 Material Weakness - I
602290 2022-002 Material Weakness - I
602291 2022-002 Material Weakness - I
602292 2022-002 Material Weakness - I
602293 2022-002 Material Weakness - I
602294 2022-002 Material Weakness - I
602295 2022-002 Material Weakness - I
602314 2022-002 Material Weakness - I
602315 2022-002 Material Weakness - I
602316 2022-002 Material Weakness - I
602317 2022-002 Material Weakness - I
602318 2022-002 Material Weakness - I
602319 2022-002 Material Weakness - I
602320 2022-002 Material Weakness - I
602321 2022-002 Material Weakness - I
602322 2022-002 Material Weakness - I
602323 2022-002 Material Weakness - I
602324 2022-002 Material Weakness - I
602325 2022-002 Material Weakness - I
602326 2022-002 Material Weakness - I
602327 2022-002 Material Weakness - I
602328 2022-002 Material Weakness - I
602329 2022-002 Material Weakness - I
602330 2022-002 Material Weakness - I
602331 2022-002 Material Weakness - I
602332 2022-002 Material Weakness - I
602333 2022-002 Material Weakness - I
602334 2022-002 Material Weakness - I
602335 2022-002 Material Weakness - I
602336 2022-002 Material Weakness - I
602337 2022-002 Material Weakness - I
602338 2022-002 Material Weakness - I
602339 2022-002 Material Weakness - I
602340 2022-002 Material Weakness - I
602341 2022-002 Material Weakness - I
602342 2022-002 Material Weakness - I
602343 2022-002 Material Weakness - I
602344 2022-002 Material Weakness - I
602345 2022-002 Material Weakness - I
602346 2022-002 Material Weakness - I
602347 2022-002 Material Weakness - I
602348 2022-002 Material Weakness - I
602349 2022-002 Material Weakness - I
602350 2022-002 Material Weakness - I
602351 2022-002 Material Weakness - I
602352 2022-002 Material Weakness - I
602353 2022-002 Material Weakness - I
602354 2022-002 Material Weakness - I
602355 2022-002 Material Weakness - I
602356 2022-002 Material Weakness - I
602357 2022-002 Material Weakness - I
602358 2022-002 Material Weakness - I
602359 2022-002 Material Weakness - I
602360 2022-002 Material Weakness - I
602361 2022-002 Material Weakness - I
602362 2022-002 Material Weakness - I
602363 2022-002 Material Weakness - I
602364 2022-002 Material Weakness - I
602365 2022-002 Material Weakness - I
602366 2022-002 Material Weakness - I
602367 2022-002 Material Weakness - I
602368 2022-002 Material Weakness - I
602369 2022-002 Material Weakness - I
602370 2022-002 Material Weakness - I
602415 2022-002 Material Weakness - I
602416 2022-002 Material Weakness - I
602417 2022-002 Material Weakness - I
602418 2022-002 Material Weakness - I
602419 2022-002 Material Weakness - I
602420 2022-002 Material Weakness - I
602421 2022-002 Material Weakness - I
602422 2022-002 Material Weakness - I
602423 2022-002 Material Weakness - I
602424 2022-002 Material Weakness - I
602425 2022-002 Material Weakness - I
602426 2022-002 Material Weakness - I
602427 2022-002 Material Weakness - I
602428 2022-002 Material Weakness - I
602429 2022-002 Material Weakness - I
602430 2022-002 Material Weakness - I
602431 2022-002 Material Weakness - I
602432 2022-002 Material Weakness - I
602433 2022-002 Material Weakness - I
602434 2022-002 Material Weakness - I
602435 2022-002 Material Weakness - I
602436 2022-002 Material Weakness - I
602437 2022-002 Material Weakness - I
602438 2022-002 Material Weakness - I
602439 2022-002 Material Weakness - I
602440 2022-002 Material Weakness - I
602441 2022-002 Material Weakness - I
602442 2022-002 Material Weakness - I
602443 2022-002 Material Weakness - I
602444 2022-002 Material Weakness - I
602445 2022-002 Material Weakness - I
602481 2022-002 Material Weakness - I
602482 2022-002 Material Weakness - I
602483 2022-002 Material Weakness - I
602484 2022-002 Material Weakness - I
602485 2022-002 Material Weakness - I
602486 2022-002 Material Weakness - I
602487 2022-002 Material Weakness - I
602488 2022-002 Material Weakness - I
602489 2022-002 Material Weakness - I
602490 2022-002 Material Weakness - I
602491 2022-002 Material Weakness - I
602492 2022-002 Material Weakness - I
602493 2022-002 Material Weakness - I
602494 2022-002 Material Weakness - I
602495 2022-002 Material Weakness - I
602496 2022-002 Material Weakness - I
602497 2022-002 Material Weakness - I
602498 2022-002 Material Weakness - I
602499 2022-002 Material Weakness - I
602500 2022-002 Material Weakness - I
602501 2022-002 Material Weakness - I
602502 2022-002 Material Weakness - I
602503 2022-002 Material Weakness - I
602504 2022-002 Material Weakness - I
602505 2022-002 Material Weakness - I
602506 2022-002 Material Weakness - I
602507 2022-002 Material Weakness - I
602508 2022-002 Material Weakness - I
602509 2022-002 Material Weakness - I
602510 2022-002 Material Weakness - I
602511 2022-002 Material Weakness - I
602512 2022-002 Material Weakness - I
602513 2022-002 Material Weakness - I
602514 2022-002 Material Weakness - I
602515 2022-002 Material Weakness - I
602516 2022-002 Material Weakness - I
602575 2022-002 Material Weakness - I
602576 2022-002 Material Weakness - I
602577 2022-002 Material Weakness - I
602578 2022-002 Material Weakness - I
602579 2022-002 Material Weakness - I
602580 2022-002 Material Weakness - I
602581 2022-002 Material Weakness - I
602582 2022-002 Material Weakness - I
602583 2022-002 Material Weakness - I
602584 2022-002 Material Weakness - I
602585 2022-002 Material Weakness - I
602586 2022-002 Material Weakness - I
602587 2022-002 Material Weakness - I
602588 2022-002 Material Weakness - I
602589 2022-002 Material Weakness - I
602590 2022-002 Material Weakness - I
602591 2022-002 Material Weakness - I
602646 2022-002 Material Weakness - I
602647 2022-002 Material Weakness - I
602648 2022-002 Material Weakness - I
602649 2022-002 Material Weakness - I
602650 2022-002 Material Weakness - I
602651 2022-002 Material Weakness - I
602652 2022-002 Material Weakness - I
602653 2022-002 Material Weakness - I
602654 2022-002 Material Weakness - I
602655 2022-002 Material Weakness - I
602656 2022-002 Material Weakness - I
602657 2022-002 Material Weakness - I
602658 2022-002 Material Weakness - I
602659 2022-002 Material Weakness - I
602660 2022-002 Material Weakness - I
602661 2022-002 Material Weakness - I
602662 2022-002 Material Weakness - I
602663 2022-002 Material Weakness - I
602664 2022-002 Material Weakness - I
602665 2022-002 Material Weakness - I
602666 2022-002 Material Weakness - I
602811 2022-002 Material Weakness - I
602812 2022-002 Material Weakness - I
602813 2022-002 Material Weakness - I
604433 2022-002 Material Weakness - I
604434 2022-002 Material Weakness - I
604435 2022-002 Material Weakness - I
604436 2022-002 Material Weakness - I
604437 2022-002 Material Weakness - I
604438 2022-002 Material Weakness - I
604439 2022-002 Material Weakness - I
604440 2022-002 Material Weakness - I
604441 2022-002 Material Weakness - I
604442 2022-002 Material Weakness - I
604443 2022-002 Material Weakness - I
604444 2022-002 Material Weakness - I
604445 2022-002 Material Weakness - I
604446 2022-002 Material Weakness - I
604447 2022-002 Material Weakness - I
604448 2022-002 Material Weakness - I
604449 2022-002 Material Weakness - I
604450 2022-002 Material Weakness - I
604451 2022-002 Material Weakness - I
604452 2022-002 Material Weakness - I
604453 2022-002 Material Weakness - I
604454 2022-002 Material Weakness - I
604455 2022-002 Material Weakness - I
604456 2022-002 Material Weakness - I
604457 2022-002 Material Weakness - I
604458 2022-002 Material Weakness - I
604459 2022-002 Material Weakness - I
604460 2022-002 Material Weakness - I
604461 2022-002 Material Weakness - I
604462 2022-002 Material Weakness - I
604463 2022-002 Material Weakness - I
604464 2022-002 Material Weakness - I
604465 2022-002 Material Weakness - I
604466 2022-002 Material Weakness - I
604467 2022-002 Material Weakness - I
604468 2022-002 Material Weakness - I
604469 2022-002 Material Weakness - I
604470 2022-002 Material Weakness - I

Programs

ALN Program Spent Major Findings
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $52.17M Yes 0
84.268 Federal Direct Student Loans $18.98M Yes 1
93.RD Covid-19 Health and Human Services Grants and Contracts/other $8.18M Yes 1
93.838 Covid-19 Lung Diseases Research $7.35M Yes 1
84.038 Federal Perkins Loan Program-Federal Capital Contributions $1.18M Yes 0
16.575 Crime Victim Assistance $986,102 - 0
12.910 Research and Technology Development $870,915 Yes 1
93.307 Minority Health and Health Disparities Research $737,698 Yes 1
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $486,106 - 0
93.396 Cancer Biology Research $475,581 Yes 1
12.800 Air Force Defense Research Sciences Program $459,900 Yes 1
93.242 Mental Health Research Grants $445,729 Yes 1
93.837 Covid-19 Cardiovascular Diseases Research $369,543 Yes 1
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $349,432 Yes 1
93.855 Covid-19 Allergy and Infectious Diseases Research $320,687 Yes 1
93.161 Health Program for Toxic Substances and Disease Registry $312,406 Yes 1
93.RD Health and Human Services Grants and Contracts/other $256,318 Yes 1
93.185 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $219,914 Yes 1
93.855 Allergy and Infectious Diseases Research $219,793 Yes 1
93.173 Research Related to Deafness and Communication Disorders $215,582 Yes 1
93.865 Child Health and Human Development Extramural Research $205,343 Yes 1
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $202,866 Yes 1
93.233 National Center on Sleep Disorders Research $201,939 Yes 1
93.393 Cancer Cause and Prevention Research $193,237 Yes 1
47.070 Computer and Information Science and Engineering $186,701 Yes 1
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students $160,133 Yes 0
43.003 Exploration $157,886 Yes 1
93.399 Cancer Control $149,837 Yes 1
93.421 Covid-19 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $147,666 Yes 1
93.461 Hrsa Covid-19 Claims Reimbursement for the Uninsured Program & the Covid-19 Coverage Assistance Fund $146,000 - 0
93.113 Environmental Health $145,943 Yes 1
12.300 Basic and Applied Scientific Research $122,723 Yes 1
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $118,397 Yes 1
93.361 Nursing Research $105,025 Yes 1
47.076 Education and Human Resources $103,389 Yes 1
12.910 Covid-19 Research and Technology Development $102,872 Yes 1
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $101,122 Yes 1
93.273 Alcohol Research Programs $100,944 Yes 1
93.994 Maternal and Child Health Services Block Grant to the States $100,725 Yes 1
93.270 Viral Hepatitis Prevention and Control $99,921 Yes 1
16.588 Violence Against Women Formula Grants $99,044 - 0
93.143 Niehs Superfund Hazardous Substances_basic Research and Education $95,322 Yes 1
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $93,422 Yes 1
93.161 Covid-19 Health Program for Toxic Substances and Disease Registry $83,163 Yes 1
84.033 Federal Work-Study Program $78,881 Yes 0
47.041 Engineering $73,726 Yes 1
93.859 Biomedical Research and Research Training $72,154 Yes 1
93.121 Oral Diseases and Disorders Research $70,255 Yes 1
93.838 Lung Diseases Research $68,922 Yes 1
93.350 Covid-19 National Center for Advancing Translational Sciences $68,700 Yes 1
93.172 Human Genome Research $61,147 Yes 1
10.215 Sustainable Agriculture Research and Education $61,018 Yes 1
93.839 Blood Diseases and Resources Research $54,077 Yes 1
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $51,855 Yes 1
93.397 Cancer Centers Support Grants $49,551 Yes 1
93.310 Trans-Nih Research Support $47,434 Yes 1
47.074 Biological Sciences $44,892 Yes 1
93.350 National Center for Advancing Translational Sciences $42,881 Yes 1
93.396 Covid-19 Cancer Biology Research $41,283 Yes 1
93.279 Drug Abuse and Addiction Research Programs $39,308 Yes 1
93.213 Research and Training in Complementary and Integrative Health $33,645 Yes 1
93.837 Cardiovascular Diseases Research $32,738 Yes 1
93.226 Research on Healthcare Costs, Quality and Outcomes $31,609 Yes 1
16.017 Sexual Assault Services Formula Program $29,683 - 0
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $29,506 Yes 1
93.866 Aging Research $29,308 Yes 1
93.136 Injury Prevention and Control Research and State and Community Based Programs $27,815 Yes 1
47.079 Covid-19 Office of International Science and Engineering $26,483 Yes 1
93.262 Occupational Safety and Health Program $23,414 Yes 1
12.420 Military Medical Research and Development $22,582 Yes 1
93.867 Vision Research $21,859 Yes 1
12.431 Basic Scientific Research $20,449 Yes 1
10.307 Organic Agriculture Research and Extension Initiative $15,988 Yes 1
93.847 Covid-19 Diabetes, Digestive, and Kidney Diseases Extramural Research $15,970 Yes 1
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $15,891 Yes 1
93.395 Cancer Treatment Research $15,638 Yes 1
93.621 Affordable Care Act Initiative to Reduce Avoidable Hospitalizations Among Nursing Facility Residents $13,720 Yes 1
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $12,999 Yes 1
93.351 Research Infrastructure Programs $10,833 Yes 1
93.398 Cancer Research Manpower $8,573 Yes 1
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $8,562 Yes 1
10.912 Environmental Quality Incentives Program $8,339 Yes 1
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $8,197 Yes 1
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $5,322 Yes 1
93.315 Rare Disorders: Research, Surveillance, Health Promotion, and Education $4,896 Yes 1
47.084 Nsf Technology, Innovation, and Partnerships $1,787 Yes 1
12.750 Covid-19 Uniformed Services University Medical Research Projects $1,715 Yes 1
93.394 Cancer Detection and Diagnosis Research $1,587 Yes 1
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $1,335 Yes 1

Contacts

Name Title Type
C8H9CNG1VBD9 Raj Appavu Auditee
6466054023 Joan Palermo Auditor
No contacts on file

Notes to SEFA

Title: Loan Programs Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of the Icahn School of Medicine at Mount Sinai (the School) and is presented on the accrual basis of accounting. The information on the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of the School. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loan and loan guarantees, or other non-cash assistance. In accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Note 4). Direct and indirect costs are charged to awards in accordance with cost principles contained in OMB Circular A-21 Cost Principles for Educational Institutions for awards not subject to the Uniform Guidance and 2 CFR 200.400 series for awards subject to the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the School did not make this election and uses a negotiated indirect cost rate. The School administers the Federal Perkins Loan Program Federal Capital Contributions (ALN 84.038). The outstanding loan balance was $1,180,191 at January 1, 2022 and there were no loan disbursements for the year ended December 31, 2022. The total balance of $1,180,191 is reported in the Schedule. The outstanding loan balance at December 31, 2022 is $832,450 .The School administers the Health Professions Student Loans, Including Primary Care Loans/Loans for Disadvantaged Students (ALN 93.342). There were no loan disbursements for the year ended December 31, 2022 and the outstanding loan balance of $160,133 at January 1, 2022 is considered current-year federal expenditures. This amount is reported in the Schedule. The outstanding loan balance at December 31, 2022 is $103,313.The School participates in the Federal Direct Student Loan Program (ALN 84.268) (which includes the Stafford and GradPlus Loan). During the year ended December 31, 2022, the School processed $18,976,607 in new loans. Since this program is administered by outside financial institutions, new loans made in the year ended December 31, 2022 relating to this program are considered current period federal expenditures, whereas the outstanding balances are not. The new loans made in the year ended December 31, 2022 are reported in the Schedule.
Title: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Payment Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of the Icahn School of Medicine at Mount Sinai (the School) and is presented on the accrual basis of accounting. The information on the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of the School. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loan and loan guarantees, or other non-cash assistance. In accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Note 4). Direct and indirect costs are charged to awards in accordance with cost principles contained in OMB Circular A-21 Cost Principles for Educational Institutions for awards not subject to the Uniform Guidance and 2 CFR 200.400 series for awards subject to the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the School did not make this election and uses a negotiated indirect cost rate. In accordance with the U.S. Department of Health and Human Services (HHS) requirements specific to, COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Payments, the amount presented on the accompanying Schedule for the year ended December 31, 2022 for Federal Assistance Listing No.(ALN) 93.498 relates to Provider Relief Fund (PRF) payments received from January 1, 2021 through December 31, 2021 used for PRF-eligible activity from the period January 1, 2020 through December 31, 2022. The amounts presented on the accompanying Schedule for the year ended December 31, 2022 reconcile to the PRF information previously reported to the Health Resources and Services Administration (HRSA) for PRF Reporting Periods 3 and 4 as follows:(See notes to SEFA for table)The lost revenues incurred by the School during the period of availability for PRF Reporting Period 3 (January 1, 2020 through June 30, 2022) and PRF Reporting Period 4 (January 1, 2020 through December 31, 2022) were in excess of the PRF distributions received from January 1, 2021 through December 31, 2021, therefore, the amounts presented in the table above and on the accompanying Schedule are limited to the amount of such distributions.

Finding Details

Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai?s exclusion screening vendor OIG Compliance Now.
Finding 2022-002 Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 ? Suspension and debarment ? Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor was not subjected to suspension and debarment evaluation procedures. Cause: Certain vendors were not subject to the School?s established suspension and debarment control. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance. Questioned Costs: None identified Context: In a sample of 40 vendors within the Research and Development procurement actions, 12 selections were not subjected to the School?s control to perform suspension and debarment evaluation. Recommendation: Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment. Views of Responsible Officials: The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the 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.