Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-002 Reporting
Identification of the Federal Program:
Grantor: Department of Education
Program Name: Student Financial Assistance Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
L. Special Reporting – Institutions must submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based loan programs (OMG No. 1845-0030). The institution uses the Fiscal Operations Report section to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. The report was due by September 29, 2023.
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
The School submitted the FISAP September 29, 2023 without the required signature of the Dean. The School resubmitted the FISAP on October 3, 2023 with the required signature.
Cause:
The FISAP was not reviewed timely as denoted by the lack of signature.
Effect or Potential Effect:
The lack of an effective control in place could lead to a late, inaccurate or incomplete submission of the FISAP and potential repercussions from the Department of Education.
Questioned Costs:
None identified
Context:
We sampled the one report submitted during fiscal year 2023 identifying the matter noted above.
Recommendation:
Management should ensure adequate processes and control are in place to complete timely review and accurate submission of the FISAP.
Views of Responsible Officials:
Management agrees with the finding described above. The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education.
Finding 2023-002 Reporting
Identification of the Federal Program:
Grantor: Department of Education
Program Name: Student Financial Assistance Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
L. Special Reporting – Institutions must submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based loan programs (OMG No. 1845-0030). The institution uses the Fiscal Operations Report section to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. The report was due by September 29, 2023.
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
The School submitted the FISAP September 29, 2023 without the required signature of the Dean. The School resubmitted the FISAP on October 3, 2023 with the required signature.
Cause:
The FISAP was not reviewed timely as denoted by the lack of signature.
Effect or Potential Effect:
The lack of an effective control in place could lead to a late, inaccurate or incomplete submission of the FISAP and potential repercussions from the Department of Education.
Questioned Costs:
None identified
Context:
We sampled the one report submitted during fiscal year 2023 identifying the matter noted above.
Recommendation:
Management should ensure adequate processes and control are in place to complete timely review and accurate submission of the FISAP.
Views of Responsible Officials:
Management agrees with the finding described above. The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education.
Finding 2023-002 Reporting
Identification of the Federal Program:
Grantor: Department of Education
Program Name: Student Financial Assistance Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
L. Special Reporting – Institutions must submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based loan programs (OMG No. 1845-0030). The institution uses the Fiscal Operations Report section to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. The report was due by September 29, 2023.
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
The School submitted the FISAP September 29, 2023 without the required signature of the Dean. The School resubmitted the FISAP on October 3, 2023 with the required signature.
Cause:
The FISAP was not reviewed timely as denoted by the lack of signature.
Effect or Potential Effect:
The lack of an effective control in place could lead to a late, inaccurate or incomplete submission of the FISAP and potential repercussions from the Department of Education.
Questioned Costs:
None identified
Context:
We sampled the one report submitted during fiscal year 2023 identifying the matter noted above.
Recommendation:
Management should ensure adequate processes and control are in place to complete timely review and accurate submission of the FISAP.
Views of Responsible Officials:
Management agrees with the finding described above. The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-002 Reporting
Identification of the Federal Program:
Grantor: Department of Education
Program Name: Student Financial Assistance Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
L. Special Reporting – Institutions must submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based loan programs (OMG No. 1845-0030). The institution uses the Fiscal Operations Report section to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. The report was due by September 29, 2023.
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
The School submitted the FISAP September 29, 2023 without the required signature of the Dean. The School resubmitted the FISAP on October 3, 2023 with the required signature.
Cause:
The FISAP was not reviewed timely as denoted by the lack of signature.
Effect or Potential Effect:
The lack of an effective control in place could lead to a late, inaccurate or incomplete submission of the FISAP and potential repercussions from the Department of Education.
Questioned Costs:
None identified
Context:
We sampled the one report submitted during fiscal year 2023 identifying the matter noted above.
Recommendation:
Management should ensure adequate processes and control are in place to complete timely review and accurate submission of the FISAP.
Views of Responsible Officials:
Management agrees with the finding described above. The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-002 Reporting
Identification of the Federal Program:
Grantor: Department of Education
Program Name: Student Financial Assistance Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
L. Special Reporting – Institutions must submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based loan programs (OMG No. 1845-0030). The institution uses the Fiscal Operations Report section to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. The report was due by September 29, 2023.
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
The School submitted the FISAP September 29, 2023 without the required signature of the Dean. The School resubmitted the FISAP on October 3, 2023 with the required signature.
Cause:
The FISAP was not reviewed timely as denoted by the lack of signature.
Effect or Potential Effect:
The lack of an effective control in place could lead to a late, inaccurate or incomplete submission of the FISAP and potential repercussions from the Department of Education.
Questioned Costs:
None identified
Context:
We sampled the one report submitted during fiscal year 2023 identifying the matter noted above.
Recommendation:
Management should ensure adequate processes and control are in place to complete timely review and accurate submission of the FISAP.
Views of Responsible Officials:
Management agrees with the finding described above. The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education.
Finding 2023-002 Reporting
Identification of the Federal Program:
Grantor: Department of Education
Program Name: Student Financial Assistance Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
L. Special Reporting – Institutions must submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based loan programs (OMG No. 1845-0030). The institution uses the Fiscal Operations Report section to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. The report was due by September 29, 2023.
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
The School submitted the FISAP September 29, 2023 without the required signature of the Dean. The School resubmitted the FISAP on October 3, 2023 with the required signature.
Cause:
The FISAP was not reviewed timely as denoted by the lack of signature.
Effect or Potential Effect:
The lack of an effective control in place could lead to a late, inaccurate or incomplete submission of the FISAP and potential repercussions from the Department of Education.
Questioned Costs:
None identified
Context:
We sampled the one report submitted during fiscal year 2023 identifying the matter noted above.
Recommendation:
Management should ensure adequate processes and control are in place to complete timely review and accurate submission of the FISAP.
Views of Responsible Officials:
Management agrees with the finding described above. The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education.
Finding 2023-002 Reporting
Identification of the Federal Program:
Grantor: Department of Education
Program Name: Student Financial Assistance Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
L. Special Reporting – Institutions must submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based loan programs (OMG No. 1845-0030). The institution uses the Fiscal Operations Report section to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. The report was due by September 29, 2023.
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
The School submitted the FISAP September 29, 2023 without the required signature of the Dean. The School resubmitted the FISAP on October 3, 2023 with the required signature.
Cause:
The FISAP was not reviewed timely as denoted by the lack of signature.
Effect or Potential Effect:
The lack of an effective control in place could lead to a late, inaccurate or incomplete submission of the FISAP and potential repercussions from the Department of Education.
Questioned Costs:
None identified
Context:
We sampled the one report submitted during fiscal year 2023 identifying the matter noted above.
Recommendation:
Management should ensure adequate processes and control are in place to complete timely review and accurate submission of the FISAP.
Views of Responsible Officials:
Management agrees with the finding described above. The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-002 Reporting
Identification of the Federal Program:
Grantor: Department of Education
Program Name: Student Financial Assistance Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
L. Special Reporting – Institutions must submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based loan programs (OMG No. 1845-0030). The institution uses the Fiscal Operations Report section to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. The report was due by September 29, 2023.
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
The School submitted the FISAP September 29, 2023 without the required signature of the Dean. The School resubmitted the FISAP on October 3, 2023 with the required signature.
Cause:
The FISAP was not reviewed timely as denoted by the lack of signature.
Effect or Potential Effect:
The lack of an effective control in place could lead to a late, inaccurate or incomplete submission of the FISAP and potential repercussions from the Department of Education.
Questioned Costs:
None identified
Context:
We sampled the one report submitted during fiscal year 2023 identifying the matter noted above.
Recommendation:
Management should ensure adequate processes and control are in place to complete timely review and accurate submission of the FISAP.
Views of Responsible Officials:
Management agrees with the finding described above. The School’s Office of Student Financial Services has instituted comprehensive processes and controls to ensure a timely review and submission of the FISAP, in accordance with the U.S. Department of Education’s FISAP instructions. The specific procedures will be documented in the School’s manual. With these protocols in place, we will adhere to the regulations set forth by the U.S. Department of Education.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.
Finding 2023-001 Procurement and Suspension and Debarment
Identification of the Federal Program:
Grantor: Department of Health and Human Services
Program Name: Research and Development Cluster
Assistance Listing No.: Various
Criteria or Specific Requirement:
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Condition:
Management has an established procurement and suspension and debarment policy to monitor vendor suspension and debarment requirements. However, management did not have an effective control in place throughout the fiscal year to evaluate suspension and debarment for all procurement actions. As a result, there were instances of procurement actions where the vendor may not have been subjected to suspension and debarment evaluation procedures.
Cause:
Certain vendors were not subject to the School’s established suspension and debarment control.
Effect or Potential Effect:
The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements.
Questioned Costs:
None identified
Context:
This is a repeat finding as denoted below. Due to the timing of the remediation of the control in the last quarter of 2023, the School’s controls were not subject to testing for the fiscal year ending December 31, 2023. A sample of 60 vendors were tested for compliance purposes during the current fiscal year. No instances of noncompliance were identified.
Identification as a repeat finding, if applicable:
Yes. Prior year finding 2022-002
Recommendation:
Management should enhance its controls to ensure that all procurement actions are subjected to an evaluation of suspension and debarment.
Views of Responsible Officials:
The Mount Sinai Health System has implemented a corrective action that includes a monthly reconciliation to ensure that all vendors are screened against various state and federal lists/registries checking for excluded, debarred and/or restricted vendors. The monthly process includes the generation of a file of all paid vendors which will be screened by Mount Sinai’s exclusion screening vendor OIG Compliance Now.