Audit 307040

FY End
2023-08-31
Total Expended
$7.21M
Findings
10
Programs
15
Organization: Change Happens! (TX)
Year: 2023 Accepted: 2024-05-23

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
398365 2023-001 Material Weakness Yes B
398366 2023-002 Significant Deficiency Yes I
398367 2023-001 Material Weakness Yes B
398368 2023-002 Significant Deficiency Yes I
398369 2023-002 Significant Deficiency Yes I
974807 2023-001 Material Weakness Yes B
974808 2023-002 Significant Deficiency Yes I
974809 2023-001 Material Weakness Yes B
974810 2023-002 Significant Deficiency Yes I
974811 2023-002 Significant Deficiency Yes I

Contacts

Name Title Type
DY23EUM3YRW5 Angelica Castillo Auditee
7133741203 Tami Preece Auditor
No contacts on file

Notes to SEFA

Title: NOTE 1 – SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: Basis of presentation – The schedule of expenditures of federal awards (the schedule) is prepared on the accrual basis of accounting. The information in the schedule is presented in accordance with the requirements of Title 2 U. S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Federal expenditures include allowable costs funded by federal grants. Allowable costs are subject to the cost principles of the Uniform Guidance and include both costs that are capitalized and costs that are recognized as expenses in Civic Heart’s financial statements in conformity with generally accepted accounting principles. Civic Heart does not have an approved indirect cost rate and does not use the 10% de minimis rate. Because the schedule presents only a selected portion of the operations of Civic Heart, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Civic Heart. De Minimis Rate Used: N Rate Explanation: The Auditee has elected not to use an indirect cost rate. Basis of presentation – The schedule of expenditures of federal awards (the schedule) is prepared on the accrual basis of accounting. The information in the schedule is presented in accordance with the requirements of Title 2 U. S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Federal expenditures include allowable costs funded by federal grants. Allowable costs are subject to the cost principles of the Uniform Guidance and include both costs that are capitalized and costs that are recognized as expenses in Civic Heart’s financial statements in conformity with generally accepted accounting principles. Civic Heart does not have an approved indirect cost rate and does not use the 10% de minimis rate. Because the schedule presents only a selected portion of the operations of Civic Heart, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Civic Heart.

Finding Details

Finding #2023-001 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Allowable costs – The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Repeat of finding #2022-001. Cause: Prior to the audit finding reported to management in May 2023, management had a lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Management is working to implement new controls and procedures to fully comply with time and effort reporting as required by Uniform Guidance. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown. Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Direct Federal Funding, Continuum of Care Program, Assistance Listing #14.267, Contract # TX0392L6E002107, Contract year: 09/01/22 – 08/31/23. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Procurement and Suspension and Debarment – The Uniform Guidance §180 prohibits contracting with parties that are suspended or debarred. The determination of whether the contracting party is suspended or debarred or otherwise excluded from participating in the transaction may be made by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration. Condition and context: Civic Heart amended its procurement policy in July 2023 to include a provision that Civic Heart will restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible. Although, Civic Heart was unable to provide evidence that such verification had been made during fiscal year 2023, we tested a sample of 13 vendors and found none to be suspended or debarred. Partial repeat of finding #2022-002. Cause: Civic Heart amended its procurement policy eleven months into fiscal year 2023 as a result of the 2022 audit finding. Although the policy was amended, the provision requiring verification of lack of suspension and debarment was not placed into service until after August 31, 2023. Effect: Failure to follow all requirements of Civic Heart’s procurement policy, including verification of lack of suspension and debarment could result in selecting vendors who are not eligible to be paid with federal monies. Recommendation: Implement procedures and provide training to personnel regarding verification that potential vendors are not debarred, suspended, or otherwise excluded from or ineligible for participation as required by their procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-001 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Allowable costs – The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Repeat of finding #2022-001. Cause: Prior to the audit finding reported to management in May 2023, management had a lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Management is working to implement new controls and procedures to fully comply with time and effort reporting as required by Uniform Guidance. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown. Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Direct Federal Funding, Continuum of Care Program, Assistance Listing #14.267, Contract # TX0392L6E002107, Contract year: 09/01/22 – 08/31/23. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Procurement and Suspension and Debarment – The Uniform Guidance §180 prohibits contracting with parties that are suspended or debarred. The determination of whether the contracting party is suspended or debarred or otherwise excluded from participating in the transaction may be made by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration. Condition and context: Civic Heart amended its procurement policy in July 2023 to include a provision that Civic Heart will restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible. Although, Civic Heart was unable to provide evidence that such verification had been made during fiscal year 2023, we tested a sample of 13 vendors and found none to be suspended or debarred. Partial repeat of finding #2022-002. Cause: Civic Heart amended its procurement policy eleven months into fiscal year 2023 as a result of the 2022 audit finding. Although the policy was amended, the provision requiring verification of lack of suspension and debarment was not placed into service until after August 31, 2023. Effect: Failure to follow all requirements of Civic Heart’s procurement policy, including verification of lack of suspension and debarment could result in selecting vendors who are not eligible to be paid with federal monies. Recommendation: Implement procedures and provide training to personnel regarding verification that potential vendors are not debarred, suspended, or otherwise excluded from or ineligible for participation as required by their procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Direct Federal Funding, Continuum of Care Program, Assistance Listing #14.267, Contract # TX0392L6E002107, Contract year: 09/01/22 – 08/31/23. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Procurement and Suspension and Debarment – The Uniform Guidance §180 prohibits contracting with parties that are suspended or debarred. The determination of whether the contracting party is suspended or debarred or otherwise excluded from participating in the transaction may be made by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration. Condition and context: Civic Heart amended its procurement policy in July 2023 to include a provision that Civic Heart will restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible. Although, Civic Heart was unable to provide evidence that such verification had been made during fiscal year 2023, we tested a sample of 13 vendors and found none to be suspended or debarred. Partial repeat of finding #2022-002. Cause: Civic Heart amended its procurement policy eleven months into fiscal year 2023 as a result of the 2022 audit finding. Although the policy was amended, the provision requiring verification of lack of suspension and debarment was not placed into service until after August 31, 2023. Effect: Failure to follow all requirements of Civic Heart’s procurement policy, including verification of lack of suspension and debarment could result in selecting vendors who are not eligible to be paid with federal monies. Recommendation: Implement procedures and provide training to personnel regarding verification that potential vendors are not debarred, suspended, or otherwise excluded from or ineligible for participation as required by their procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-001 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Allowable costs – The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Repeat of finding #2022-001. Cause: Prior to the audit finding reported to management in May 2023, management had a lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Management is working to implement new controls and procedures to fully comply with time and effort reporting as required by Uniform Guidance. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown. Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Direct Federal Funding, Continuum of Care Program, Assistance Listing #14.267, Contract # TX0392L6E002107, Contract year: 09/01/22 – 08/31/23. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Procurement and Suspension and Debarment – The Uniform Guidance §180 prohibits contracting with parties that are suspended or debarred. The determination of whether the contracting party is suspended or debarred or otherwise excluded from participating in the transaction may be made by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration. Condition and context: Civic Heart amended its procurement policy in July 2023 to include a provision that Civic Heart will restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible. Although, Civic Heart was unable to provide evidence that such verification had been made during fiscal year 2023, we tested a sample of 13 vendors and found none to be suspended or debarred. Partial repeat of finding #2022-002. Cause: Civic Heart amended its procurement policy eleven months into fiscal year 2023 as a result of the 2022 audit finding. Although the policy was amended, the provision requiring verification of lack of suspension and debarment was not placed into service until after August 31, 2023. Effect: Failure to follow all requirements of Civic Heart’s procurement policy, including verification of lack of suspension and debarment could result in selecting vendors who are not eligible to be paid with federal monies. Recommendation: Implement procedures and provide training to personnel regarding verification that potential vendors are not debarred, suspended, or otherwise excluded from or ineligible for participation as required by their procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-001 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Allowable costs – The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Repeat of finding #2022-001. Cause: Prior to the audit finding reported to management in May 2023, management had a lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Management is working to implement new controls and procedures to fully comply with time and effort reporting as required by Uniform Guidance. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown. Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Direct Federal Funding, Continuum of Care Program, Assistance Listing #14.267, Contract # TX0392L6E002107, Contract year: 09/01/22 – 08/31/23. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Procurement and Suspension and Debarment – The Uniform Guidance §180 prohibits contracting with parties that are suspended or debarred. The determination of whether the contracting party is suspended or debarred or otherwise excluded from participating in the transaction may be made by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration. Condition and context: Civic Heart amended its procurement policy in July 2023 to include a provision that Civic Heart will restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible. Although, Civic Heart was unable to provide evidence that such verification had been made during fiscal year 2023, we tested a sample of 13 vendors and found none to be suspended or debarred. Partial repeat of finding #2022-002. Cause: Civic Heart amended its procurement policy eleven months into fiscal year 2023 as a result of the 2022 audit finding. Although the policy was amended, the provision requiring verification of lack of suspension and debarment was not placed into service until after August 31, 2023. Effect: Failure to follow all requirements of Civic Heart’s procurement policy, including verification of lack of suspension and debarment could result in selecting vendors who are not eligible to be paid with federal monies. Recommendation: Implement procedures and provide training to personnel regarding verification that potential vendors are not debarred, suspended, or otherwise excluded from or ineligible for participation as required by their procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Direct Federal Funding, Continuum of Care Program, Assistance Listing #14.267, Contract # TX0392L6E002107, Contract year: 09/01/22 – 08/31/23. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Procurement and Suspension and Debarment – The Uniform Guidance §180 prohibits contracting with parties that are suspended or debarred. The determination of whether the contracting party is suspended or debarred or otherwise excluded from participating in the transaction may be made by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration. Condition and context: Civic Heart amended its procurement policy in July 2023 to include a provision that Civic Heart will restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible. Although, Civic Heart was unable to provide evidence that such verification had been made during fiscal year 2023, we tested a sample of 13 vendors and found none to be suspended or debarred. Partial repeat of finding #2022-002. Cause: Civic Heart amended its procurement policy eleven months into fiscal year 2023 as a result of the 2022 audit finding. Although the policy was amended, the provision requiring verification of lack of suspension and debarment was not placed into service until after August 31, 2023. Effect: Failure to follow all requirements of Civic Heart’s procurement policy, including verification of lack of suspension and debarment could result in selecting vendors who are not eligible to be paid with federal monies. Recommendation: Implement procedures and provide training to personnel regarding verification that potential vendors are not debarred, suspended, or otherwise excluded from or ineligible for participation as required by their procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.