Audit 321761

FY End
2023-12-31
Total Expended
$77.28M
Findings
66
Programs
17
Year: 2023 Accepted: 2024-09-27

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
498921 2023-001 Significant Deficiency - I
498922 2023-001 Significant Deficiency - I
498923 2023-001 Significant Deficiency - I
498924 2023-001 Significant Deficiency - I
498925 2023-001 Significant Deficiency - I
498926 2023-001 Significant Deficiency - I
498927 2023-001 Significant Deficiency - I
498928 2023-001 Significant Deficiency - I
498929 2023-001 Significant Deficiency - I
498930 2023-001 Significant Deficiency - I
498931 2023-001 Significant Deficiency - I
498932 2023-001 Significant Deficiency - I
498933 2023-001 Significant Deficiency - I
498934 2023-001 Significant Deficiency - I
498935 2023-001 Significant Deficiency - I
498936 2023-001 Significant Deficiency - I
498937 2023-001 Significant Deficiency - I
498938 2023-001 Significant Deficiency - I
498939 2023-001 Significant Deficiency - I
498940 2023-001 Significant Deficiency - I
498941 2023-001 Significant Deficiency - I
498942 2023-001 Significant Deficiency - I
498943 2023-001 Significant Deficiency - I
498944 2023-001 Significant Deficiency - I
498945 2023-001 Significant Deficiency - I
498946 2023-001 Significant Deficiency - I
498947 2023-001 Significant Deficiency - I
498948 2023-001 Significant Deficiency - I
498949 2023-001 Significant Deficiency - I
498950 2023-001 Significant Deficiency - I
498951 2023-001 Significant Deficiency - I
498952 2023-001 Significant Deficiency - I
498953 2023-001 Significant Deficiency - I
1075363 2023-001 Significant Deficiency - I
1075364 2023-001 Significant Deficiency - I
1075365 2023-001 Significant Deficiency - I
1075366 2023-001 Significant Deficiency - I
1075367 2023-001 Significant Deficiency - I
1075368 2023-001 Significant Deficiency - I
1075369 2023-001 Significant Deficiency - I
1075370 2023-001 Significant Deficiency - I
1075371 2023-001 Significant Deficiency - I
1075372 2023-001 Significant Deficiency - I
1075373 2023-001 Significant Deficiency - I
1075374 2023-001 Significant Deficiency - I
1075375 2023-001 Significant Deficiency - I
1075376 2023-001 Significant Deficiency - I
1075377 2023-001 Significant Deficiency - I
1075378 2023-001 Significant Deficiency - I
1075379 2023-001 Significant Deficiency - I
1075380 2023-001 Significant Deficiency - I
1075381 2023-001 Significant Deficiency - I
1075382 2023-001 Significant Deficiency - I
1075383 2023-001 Significant Deficiency - I
1075384 2023-001 Significant Deficiency - I
1075385 2023-001 Significant Deficiency - I
1075386 2023-001 Significant Deficiency - I
1075387 2023-001 Significant Deficiency - I
1075388 2023-001 Significant Deficiency - I
1075389 2023-001 Significant Deficiency - I
1075390 2023-001 Significant Deficiency - I
1075391 2023-001 Significant Deficiency - I
1075392 2023-001 Significant Deficiency - I
1075393 2023-001 Significant Deficiency - I
1075394 2023-001 Significant Deficiency - I
1075395 2023-001 Significant Deficiency - I

Contacts

Name Title Type
DASAFLTJUTD6 Joy Block-Gonzalez Auditee
4073573318 Karthik Ramaswamy Auditor
No contacts on file

Notes to SEFA

Title: 1. Basis of Presentation Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Adventist Health System Sunbelt Healthcare Corporation d/b/a AdventHealth (the System) under programs of the federal government for the year ended December 31, 2023. The information in 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 (Uniform Guidance). Expenditures reported on the Schedule are reported on the accrual basis of accounting. Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the combined financial position, results of operations or cash flows of the System. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Adventist Health System Sunbelt Healthcare Corporation d/b/a AdventHealth (the System) under programs of the federal government for the year ended December 31, 2023. The information in 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 (Uniform Guidance). Expenditures reported on the Schedule are reported on the accrual basis of accounting. Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the combined financial position, results of operations or cash flows of the System.
Title: 2. 10% De Minimis Cost Rate Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Adventist Health System Sunbelt Healthcare Corporation d/b/a AdventHealth (the System) under programs of the federal government for the year ended December 31, 2023. The information in 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 (Uniform Guidance). Expenditures reported on the Schedule are reported on the accrual basis of accounting. Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the combined financial position, results of operations or cash flows of the System. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: 3. Reporting Entity Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Adventist Health System Sunbelt Healthcare Corporation d/b/a AdventHealth (the System) under programs of the federal government for the year ended December 31, 2023. The information in 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 (Uniform Guidance). Expenditures reported on the Schedule are reported on the accrual basis of accounting. Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the combined financial position, results of operations or cash flows of the System. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The System’s reporting entity is defined in Note 1 to the System’s consolidated financial statements. For the year ended December 31, 2023, federal expenditures related to the following entity was not included in the System’s total federal expenditures reported in the Schedule. This entity has a separate financial statement audit, and, as such, its expenditures are subject to the requirements of the Uniform Guidance at that reporting level. The entity not included in the Schedule is as follows: • Adventist University of Health Sciences, Inc. d/b/a AdventHealth University
Title: 4. Contingencies Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Adventist Health System Sunbelt Healthcare Corporation d/b/a AdventHealth (the System) under programs of the federal government for the year ended December 31, 2023. The information in 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 (Uniform Guidance). Expenditures reported on the Schedule are reported on the accrual basis of accounting. Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the combined financial position, results of operations or cash flows of the System. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Grant monies received and disbursed by the System are for specific purposes and are subject to audit by the grantor agencies. Such audits may result in requests for reimbursement due to disallowed expenditures. The System does not believe that such disallowances, if any, would have a material effect on the consolidated financial position of the System.
Title: 5. COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (Assistance Listing No. 93.498) Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Adventist Health System Sunbelt Healthcare Corporation d/b/a AdventHealth (the System) under programs of the federal government for the year ended December 31, 2023. The information in 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 (Uniform Guidance). Expenditures reported on the Schedule are reported on the accrual basis of accounting. Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the combined financial position, results of operations or cash flows of the System. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The Schedule includes $64,451,227 received from the Department of Health and Human Services (HHS) between January 1, 2022 through December 31, 2022, under the Provider Relief Fund (PRF) program of Assistance Listing No. 93.498. In accordance with guidance from HHS, $11,469 in interest income earned on funds received from HHS has been included as a reportable PRF payment. These amounts are reported as Period 5 and Period 6 in the HHS PRF Reporting Portal. These amounts were recognized as other revenue and investment income in the System’s consolidated financial statements in the accompanying consolidated statements of operations and changes in net assets for the years ended December 31, 2023, and 2022. The amount presented on the Schedule for PRF is for the year ended December 31, 2023. The amount presented reconciles to the PRF information reported to HHS as follows: Name of Reporting Entity for HHS Reporting Periods 5 and 6 Provider Relief Fund Report Reporting Entity Tax Identification Number (TIN) Type of Distribution Total Lost Revenues and Expenditures Reported Florida Hospital Medical Group, Inc. 593214635 General $ 1,536,528 Metroplex Clinic Physicians, Inc. 113762050 General 16,104 AHP Specialty Care, NFP 811105774 General 7,319 AdventHealth Family Medicine Rural Health Clinics, Inc. 271858033 General 27,859 Fountain Inn Nursing & Rehab Center, Inc. 472180518 General 23,545 AdventHealth Polk North, Inc. 841793121 General 153,802 Adventist Health System/Sunbelt, Inc. DBA AdventHealth Orlando 590724459 General 53,296,558 AdventHealth Ransom Memorial, Inc. 830976641 General 59,095 University Community Hospital, Inc. 591113901 General 8,789,622 Tri-County Nursing and Rehab Center, Inc. 472219363 General 540,795 $ 64,451,227
Title: 6. Disaster Grants - Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Adventist Health System Sunbelt Healthcare Corporation d/b/a AdventHealth (the System) under programs of the federal government for the year ended December 31, 2023. The information in 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 (Uniform Guidance). Expenditures reported on the Schedule are reported on the accrual basis of accounting. Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the combined financial position, results of operations or cash flows of the System. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures for Disaster Grants from the U.S. Department of Homeland Security are recorded on the Schedule when the funds are obligated by the federal agency through the approval of the Project Worksheets and eligible expenditures have been incurred, and are presented net of estimated insurance recoveries, if any. Out of the total Disaster grant expenditures ($5,260,551) included in the Schedule for the year ended December 31, 2023, expenditures that were incurred in prior fiscal years were $5,253,912.

Finding Details

Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.
Finding 2023-001 Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The Non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the 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: We noted the following matters during our testing of suspension and debarment control processes: (a) AdventHealth utilizes a third-party service provider to perform on-going monitoring and screening of its vendors and suppliers for suspension and debarment. AdventHealth relied on the results of the suspension and debarment checks performed by the third-party service provider without having a validation control to ensure the results provided by the third_x0002_party service provider were accurate. The third-party service provider does not have a SOC 1 (System and Organization Controls) Report. (b) AdventHealth does not receive a listing, from the third-party service provider, of all vendors and suppliers screened on a monthly basis. While AdventHealth does receive a listing of vendors and suppliers with a “match” or “potential match”, since the full listing of all vendors and suppliers screened was not available, it could not be determined whether all vendors and suppliers were appropriately screened by the third-party service provider. On an annual basis, AdventHealth did receive the full listing of all vendors and suppliers that were screened for suspension and debarment by the third-party service provider. However, a reconciliation between the vendor and supplier list provided by AdventHealth and the list that is received from the third-party service provider was not performed. Cause: AdventHealth did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party service provider aligned with the governmental suspension and debarment database when the search resulted in no match. In addition, AdventHealth did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor and supplier list sent to the third-party service provider and the results provided by the third-party service provider. Effect or Potential Effect: AdventHealth’s screening for suspension and debarment through the third-party service provider may not be accurate. By not performing a reconciliation between the vendor and supplier list in AdventHealth’s database and the results provided by the third-party service provider, there exists a risk that certain vendors and suppliers were not screened by the third-party service provider. Questioned costs: None Context: AdventHealth, as part of its internal control process, internally performs screening for all “new” vendors and suppliers prior to adding them in the database. We tested 40 new vendors that were added to the database in fiscal year 2023 and found no issues. As such, there exists a process to ensure that only valid and appropriately screened vendors and suppliers are contracted with. Since the issue relates to the on-going monitoring performed by the third-party service provider, for which appropriate controls were not put in place, this resulted in a deficiency in internal control process. The federal portion of expenditures subject to suspension and debarment was approximately $354,000, which represents approximately 5.5% of the total Research and Development Cluster federal expenditures. The total amount reported on the SEFA for R&D cluster is $6,392,558. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management should implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Views of Responsible Officials: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed.