Audit 320498

Finding: Suspension and Debarment U.S. Department of the Treasury Passed through Missouri Primary Care Association Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Fund Award Year: 2022 Award Number: SLFPR4542 Criteria or Specific Requirement In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Part 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Proper verification of vendors was not occurring prior to purchase to determine whether vendors were suspended or debarred. Questioned Costs - None noted. Context: One transaction selected for testing the suspension and debarment verification occurred subsequent to the purchase. Identification of Prior Year Finding: N/A Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: Vendors subject to suspension and debarment requirements are entered into Compilatric, a 3rd party software, to run monthly exclusion checks. Compilatric checks with the OIG, SAM, and GAS, plus about 35 other state and federal databases that host suspended and disbarred lists. The purchase from this vendor was not communicated to the correct department timely and a check was inadvertently missed. Recommendation: We recommend that the Health Center communicate to all departments that purchases using federal funds have suspension and debarment checks completed prior to purchase. View of Responsible Official and Planned Corrective Actions: The Health Center agrees with the finding. See separate report for planned corrective actions.

Finding: Suspension and Debarment U.S. Department of the Treasury Passed through Missouri Primary Care Association Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Fund Award Year: 2022 Award Number: SLFPR4542 Criteria or Specific Requirement In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Part 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Proper verification of vendors was not occurring prior to purchase to determine whether vendors were suspended or debarred. Questioned Costs - None noted. Context: One transaction selected for testing the suspension and debarment verification occurred subsequent to the purchase. Identification of Prior Year Finding: N/A Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: Vendors subject to suspension and debarment requirements are entered into Compilatric, a 3rd party software, to run monthly exclusion checks. Compilatric checks with the OIG, SAM, and GAS, plus about 35 other state and federal databases that host suspended and disbarred lists. The purchase from this vendor was not communicated to the correct department timely and a check was inadvertently missed. Recommendation: We recommend that the Health Center communicate to all departments that purchases using federal funds have suspension and debarment checks completed prior to purchase. View of Responsible Official and Planned Corrective Actions: The Health Center agrees with the finding. See separate report for planned corrective actions.