Audit 379897

Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Rural Health Cooperative Agreement FAL Number: 93.241 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 9/1/22 – 8/31/27 Type of Finding:  Significant Deficiency in Internal Control over Compliance, and Other Matters Criteria or Specific Requirement: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing we noted the Organization did not apply its suspension and debarment procedures for two contractors sampled prior to entering into the contract. Questioned Costs: N/A Context: Two out of five selections did not have any suspension/debarment procedures followed until after entering into the covered transaction. Cause: Management was aware of the suspension and debarment requirements dictated by the Uniform Guidance, however, did not follow their policy. Effect: Potential for the Organization to do business with entities that are suspended or debarred which is not allowed per Uniform Guidance. Repeat Finding: No Recommendation: The Organization should ensure they follow their policy to check for suspension and debarment prior to entering into the contract. Views of responsible officials and planned corrective actions: There are no disagreements with the audit finding. The Organization will ensure they follow their suspension and debarment policy moving forward and documentation is retained.