Federal Agency: U.S. Department of Interior CFDA Program: 15.875 Economic, Social, and Political Development of the Territories Award Number: D18AP00138 and D20AP00049 Area: Equipment and Real Property Management Questioned Costs: Undeterminable Criteria: In accordance with 2 CFR 200.313(b), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and regulations. The CHCC Operating Policy: Fixed Asset/Property Changes requires the CHCC Property Management Branch to perform an annual physical inventory of all fixed assets/property and to document and control all changes in fixed assets/property. Further, in accordance with 2 CFR 200.313(d)(1), property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. Lastly, 2 CFR 200.313(d)(3) requires that adequate maintenance procedures must be developed to keep the property in good condition. Condition: For 11 (or 100%) of 11 capital assets selected for testing, the following were noted: 1. CHCC did not provide any supporting documentation that a physical inventory count was performed in FY2020. No questioned costs are presented as we are not able to quantify the extent of noncompliance. 2. CHCC’s capital assets listing does not include all the required information for equipment and real property that is in accordance with 2 CFR 200.313(d)(1). No questioned costs are presented as we are not able to quantify the extent of noncompliance 3. Capital asset items could not be traced to the results of the periodic maintenance procedures performed. No questioned costs are presented as we are not able to quantify the extent of noncompliance. Cause: 1. CHCC’s current policy and procedure for capital asset listing management and maintenance are not in accordance with the federal requirements stated in 2 CFR 200.313(d)(1). 2. CHCC’s document maintenance and retention controls did not operate as designed to ensure that the recorded results of the physical inventory and maintenance procedures are stored properly and that documents are easily retrieved. 3. The results of CHCC’s periodic maintenance procedures lack unique identifiers necessary to trace the selected samples between the capital assets listing and the maintenance results Effect: CHCC is in noncompliance with applicable Equipment and Real Property Management requirements. Questioned costs are undetermined as we are unable to quantify the extent of noncompliance. Recommendation: 1. CHCC should update the structure and contents of their current capital asset listing to include all the information required by 2 CFR 200.313(d)(1). Additionally, CHCC should improve their policies and procedures on management and maintenance of their capital asset listing. 2. CHCC should implement more stringent policies and procedures in relation to their document maintenance and retention to ensure that documents are easily retrieved and provided in a timely manner. 3. CHCC should ensure that the results of the periodic maintenance procedures include all information, including unique identifiers for capital assets, necessary to properly and timely trace capital assets between the capital assets listing and the maintenance results listing. Views of Responsible Officials: CHCC concurs with the findings. CHCC will update its Capital Assets policy to comply with the requirements of 2 CFR 200.313. Furthermore, CHCC will ensure that there is a clear crosswalk between the Preventive Maintenance Record with our Facilities Department and the Capital Assets listing that is revised pursuant to the requirements of 2 CFR 200.313. CHCC would like to clarify that although the documentation fell short of the Uniform Guidance documentation, all the physical existence and working conditions were verifiable during the audit.
Federal Agency: U.S. Department of Interior CFDA Program: 15.875 Economic, Social, and Political Development of the Territories Award Number: D18AP00137 and D20AP00049 Area: Procurement and Suspension and Debarment Questioned Costs: $551,917 Criteria: In accordance with 2 CFR 180.300, entities that enter into covered transactions must verify that the person with whom they intend to do business is not excluded or disqualified by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, according to 2 CFR 180.220(b)(1), a procurement transaction is considered a covered transaction if the contract amount is expected or to equal or exceed $25,000. Condition: CHCC did not verify whether a person or a vendor is excluded or disqualified pursuant to the requirements of 2 CFR 180.300 prior to entering into the following covered transactions that exceeded the $25,000 threshold. Cause: CHCC’s current policy or procedure for suspension and debarment monitoring only applies to newly contracted persons or vendors under a covered transaction, thus not pursuant to the requirements or provisions of 2 CFR 180.300. Effect: CHCC is in noncompliance with applicable suspension and debarment regulations and questioned costs of $551,917 result. Recommendation: CHCC should revise or update their policies and procedures for monitoring suspension and debarment status of each vendor of covered transactions. These should be reflective of the requirements set by 2 CFR 180.300. Views of Responsible Officials: CHCC concurs with the findings but not the questioned costs. CHCC Division Grants and Financial Integrity (DGFI), updated our Suspension and Debarment procedure to comply with 2 CFR 180.300. To address the question cost of $551,917, CHCC imported from SAM.gov the Exclusion reports dated April 2020 and October 2020 and confirmed that none of the vendors cited in this finding are in the list of excluded vendors. Auditor Response: In accordance with 2 CFR 2900.3(a), a questioned cost is defined as a possible violation of statute, regulation, or the terms and conditions of a Federal award. The current process of CHCC monitoring suspension and debarment status of each vendor or supplier under a covered transaction is not designed to be in accordance with the provisions stated in 2 CFR 180.300 which is the statute to be followed as identified in the terms and conditions of the federal awards. As such, we retain the questioned costs.
Federal Agency: U.S. Department of Interior CFDA Program: 15.875 Economic, Social, and Political Development of the Territories Award Number: D18AP00137 and D19AP00132 Area: Reporting Questioned Costs: $-0- Criteria: In accordance with the applicable reporting requirements, an SF-425 report is required to be submitted on a semi-annual basis for non-expired or non-terminated grants. Condition: For two (or 40%) of five reports tested, CHCC did not submit the required semi-annual SF-425 reports during the year. Cause: CHCC failed to properly implement their current policies and procedures for SF-425 reporting submission monitoring. Effect: CHCC is in noncompliance with applicable reporting requirements but no questioned cost results as the finding is non-monetary in nature. Recommendation: CHCC should implement more stringent actions to properly enforce their current controls and procedures in monitoring the submission of all required SF-425 reports. Views of Responsible Officials: CHCC partially concurs with the findings as the Director of DGFI provided the SF-425 for Grant D19AP00132 to the auditor during fieldwork. CHCC will strictly enforce our established policies and procedures to ensure timely submissions of the SF-425 and other post award reports required for our Federal Grants. Auditor Response: Based on terms and conditions of grant D19AP00132, the SF-425 reports are required to be submitted on a semi-annual basis. Only one report, the first semi-annual report, was provided during fieldwork. Further, we received confirmation from CHCC that the reports provided, which did not include the SF-425 reports for grant D19AP00132, were the only submissions during FY 2020. Finding remains.
Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Administration Award Number: 1H79SM081982-01 and 5H79SM081982-02 Area: Equipment and Real Property Management Questioned Costs: Undeterminable Criteria: In accordance with 2 CFR 200.313(b), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and regulations. The CHCC Operating Policy: Fixed Asset/Property Changes requires the CHCC Property Management Branch to perform an annual physical inventory of all fixed assets/property and to document and control all changes in fixed assets/property. Further, in accordance with 2 CFR 200.313(d)(1), property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. Lastly, 2 CFR 200.313 (d)(3) requires that adequate maintenance procedures must be developed to keep the property in good condition. Condition: For five (or 100%) of five capital assets selected for testing, the following were noted: 1. CHCC did not provide any supporting documentation that a physical inventory count was performed in FY2020. No questioned costs are presented as we are not able to quantify the extent of noncompliance. 2. CHCC’s capital assets listing does not include all the required information for equipment and real property that is in accordance with 2 CFR 200.313(d)(1). No questioned costs are presented as we are not able to quantify the extent of noncompliance. 3. Capital asset items could not be traced to the results of the periodic maintenance procedures performed. No questioned costs are presented as we are not able to quantify the extent of noncompliance. Cause: 1. CHCC’s current policy and procedure for capital asset listing management and maintenance is not in accordance with the federal requirements stated in 2 CFR 200.313(d)(1). 2. CHCC’s document maintenance and retention controls did not operate as designed to ensure that the recorded results of the physical inventory and maintenance procedures are stored properly and that documents are easily retrieved. 3. The results of CHCC’s periodic maintenance procedures lack unique identifiers necessary to trace the selected samples between the capital assets listing and the maintenance results. Effect: CHCC is in noncompliance with applicable Equipment and Real Property Management requirements. Questioned costs are undetermined as we are unable to quantify the extent of noncompliance. Recommendation: 1. CHCC should update the structure and contents of their current capital asset listing to include all the information required by 2 CFR 200.313(d)(1). Additionally, CHCC should improve their policies and procedures on management and maintenance of their capital asset listing. 2. CHCC should implement more stringent policies and procedures in relation to their document maintenance and retention to ensure that documents are easily retrieved and provided in a timely manner. 3. CHCC should ensure that the results of the periodic maintenance procedures include all information, including unique identifiers for capital assets, necessary to properly and timely trace capital assets between the capital assets listing and the maintenance results listing. Views of Responsible Officials: CHCC concurs with the findings. CHCC will update its Capital Assets policy to comply with the requirements of 2 CFR 200.313. Furthermore, CHCC will ensure that there is a clear crosswalk between the Preventive Maintenance Record with our Facilities Department and the Capital Assets listing that is revised pursuant to the requirements of 2 CFR 200.313. CHCC would like to clarify that although the documentation fell short of the Uniform Guidance documentation, all the physical existence and working conditions were verifiable during the audit.
Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 1H79SM081982-01 Area: Procurement and Suspension and Debarment Questioned Costs: $107,645 Criteria: In accordance with 2 CFR 180.300, entities that enter into covered transactions must verify that the person with whom they intend to do business is not excluded or disqualified by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, according to 2 CFR 180.220(b)(1), a procurement transaction is considered a covered transaction if the contract amount is expected or to equal or exceed $25,000. Condition: CHCC did not verify whether a person or a vendor is excluded or disqualified pursuant to the requirements of 2 CFR 180.300 prior to entering into the following covered transactions that exceeded the $25,000 threshold. Cause: CHCC’s current policy or procedure for suspension and debarment monitoring only applies to newly contracted persons or vendors under a covered transaction, thus not pursuant to the requirements or provisions of 2 CFR 180.300. Effect: CHCC is in noncompliance with applicable suspension and debarment regulations and questioned costs of $107,645 result. Recommendation: CHCC should revise or update their policies and procedures for monitoring suspension and debarment status of each vendor of covered transactions. These should be reflective of the requirements set by 2 CFR 180.300. Views of Responsible Officials: CHCC concurs with the findings but not the questioned costs. CHCC Division Grants and Financial Integrity (DGFI), updated our Suspension and Debarment procedure to comply with 2 CFR 180.300. To address the question cost of $107,645, CHCC imported from SAM.gov the Exclusion reports dated April 2020 and October 2020 and confirmed that none of the vendors cited in this finding are in the list of excluded vendors. Auditor Response: In accordance with 2 CFR 2900.3(a), a questioned cost is defined as a possible violation of statute, regulation, or the terms and conditions of a Federal award. The current process of CHCC monitoring suspension and debarment status of each vendor or supplier under a covered transaction is not designed to be in accordance with the provisions stated in 2 CFR 180.300 which is the statute to be followed as identified in the terms and conditions of the federal awards. As such, we retain the questioned costs.
Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreement Award Number: 1NH23IP922587-01 Area: Period of Performance Questioned Costs: $4,343 Criteria: In accordance with 45 CFR 75.309, a non-federal entity may charge to the federal award only allowable costs incurred during the period of performance and any costs incurred before the U.S. Department of Health and Human Services (HHS) awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Funds available to pay allowable costs during the period of performance include both federal funds awarded and the carryover balances. Condition: For two (or 8%) of twenty-five expenditures tested, aggregating $13,462, of total population of $132,807, expenditures were obligated after the end of period of performance of the related grant awards. Cause: CHCC incurred these expenditures prior to an approved PO. CHCC failed to follow the correct sequence of their PO approval process, resulting in obligating transactions after the end of the period of performance of the grant as an approved PO is required to process the payments. Effect: CHCC is in noncompliance with applicable period of performance requirements and questioned costs of $4,343 result. Identification as a Repeat Finding: Finding No. 2019-014 Recommendation: 1. CHCC should strictly follow their established policies and procedures related to PO approval, which includes checking the grant status to ensure that obligations are incurred prior to the end of the POP of the related grant. 2. CHCC should establish more stringent monitoring procedures to ensure that no expenditures are incurred prior to receiving an approval of the PO. Views of Responsible Officials: CHCC does not concur with the findings and the cost questioned. The transactions cited were for emergency repairs of Vaccine Refrigerators. The repairs were done within the period of performance ending June 30, 2020 ($2,990 was for Service date of December 20, 2019; and $1,353 was for service date February 28, 2020) No purchase order was prepared for the emergency service. A ratification memo was approved for payment processing by the Chief Financial Officer and the Chief Executive Officer. CHCC believes that the repairs on the Refrigerators that are used to store vaccines are reasonable and necessary, especially during the period wherein we are responding to the COVID-19. Auditor Response: The purchase order date, which signifies when a transaction is obligated, was beyond the period of performance. Additionally, the ratification memo was approved by the CEO on September 25, 2020, which was also beyond the period of performance. Finding remains.
Federal Agency: Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreement Award Number: 1NH23IP922587-01-00, 6NH23IP922587-01-01, 6NH23IP922587-01-02, 5NH23IP922587-02-00, 6 NH23IP922587-02-01 and 6NH23IP000736 Area: Special Tests and Provision – Control, Accountability and Safeguarding of Vaccine Questioned Costs: $ -0- Criteria: In accordance with the Vaccine for Children Program (VFC) Policies and Procedures at the State/Local Immunization Program section 5.2.7, CHCC is required to conduct monthly reconciliation of the vaccination records which includes the vaccine inventory, patient screening forms, vaccine administered log sheet and the temperature log sheet. Additionally, in accordance with the VFC Policies and Procedures at the State/Local Immunization Program section 4.1, visits must be conducted on an annual or as per need basis which evaluates the program’s adherence to VFC program requirements, including appropriate vaccine handling, storage, and ordering procedures. CHCC is required to perform sampling of patient records to verify eligibility screening and the administration of VFC vaccine only to eligible children. Condition: 1. For 12 (or 100%) of 12 monthly provider inventory reconciliations selected for testing, no supporting documentation was provided to evidence that reviews and approvals were conducted by CHCC over the reconciliations. Condition, continued: 2. For five (or 83%) of six providers selected for testing, CHCC was unable to provide the annual Site Visit Reports. Cause: CHCC was unable to provide the supporting documents as it was lost during the transition to the new management and their current control and procedures are not suitably designed to properly maintain and retain all the documents. Effect: The CHCC is in noncompliance with the applicable Special Tests and Provisions – Control, Accountability and Safeguarding of Vaccine. Recommendation: CHCC should improve their record-keeping policies and controls, such as duplication of documents into a soft copy, to ensure that a seamless transition is achieved whenever changes to management take into effect. Views of Responsible Officials: CHCC concurs with the findings. To address this finding, the Immunization Program conducts the following reconciliation of vaccination records as follows: Vaccination records: daily entries of vaccination records are captured through the patient encounter form for all providers administering vaccinations. Data Entry Assistants and Program Assistants are responsible for entering the vaccinations based on the form. The Immunization Information Systems (IIS) team are responsible for ensuring data quality elements are complete on the form and reflected on the WebIZ system. Patient screening forms: also known as the patient encounter form is the paper-based document in which patient demographics and vaccination data elements are recorded upon visit for all providers. Data Entry Assistant and Program Assistant capture demographic and input vaccines an individual is to receive for the visit. The vaccinator then inputs vaccination data elements (lot number, manufacturer, site, route, etc.) to be inputted into the registry, WebIZ. Temperature log: utilized to document the vaccine storage unit temperature based on the thermometer reading and logged at the start and end of each workday, as well as after hours and weekends/holidays. The VFC Coordinator and Security team logs the temperatures on a daily, routine basis. Vaccine inventory: monitored weekly by the Logistics Technician via spreadsheet and tracked using the registry WebIZ for overall vaccine inventory management. Inventory is reported to CDC by the Program Manager every 14 days. Vaccine wastage from all providers is submitted to the program at the first week of each month for the previous month reporting period. Overall wastage reporting is done monthly to CDC. In addition, since 2020, CHCC has conducted the following steps to ensure that annual site visits for VFC providers are completed and documented appropriately to evaluate adherence to the VFC program requirements: - Provided training to the staff member assigned/responsible (VFC Coordinator) for conducting site visits - Worked with CDC Subject Matter Experts to ensure that data systems for site visit findings/reporting were accessible to the VFC Coordinator. Training on the system was also provided to the VFC Coordinator. This system is cloud based and accessible to anyone provided access. Therefore, should staff turnover occur, access to prior reports and the system for submitting new site visit reports will continue to be accessible to the organization and to team members who will take on the responsibility. - Ensure that Position Description for the VFC Coordinator clearly specify responsibilities for implementing the VFC Program in accordance with the Immunization Program Operating Manual (IPOM), which outlines the requirements for annual provider compliance site visits, including the sampling of patient records to verify eligibility screening and administration of VFC vaccine only to eligible children. - Entries of vaccine reconciliation documentation such as vaccine inventory (orders, transfers, and wastages) are accessible on the registry, CNMI WebIZ, as well as routine reporting to CDC VtrckS
Federal Agency: Department of Health and Human Services CFDA Program: 93.268 Immunization Cooperative Agreement Award Number: 1NH23IP922587-01-00, 6NH23IP922587-01-01, 6NH23IP922587-01-02, 5NH23IP922587-02-00, 6 NH23IP922587-02-01 and 6NH23IP000736 Area: Special Tests and Provision – Record of Immunization Questioned Costs: $ -0- Criteria: In accordance with the Vaccine for Children Program (VFC) Policies and Procedures at the State/Local Immunization Program section 4.1, visits must be conducted on an annual or as per need basis which evaluates the program’s adherence to VFC program requirements including sampling patient records to verify eligibility screening and the administration of VFC vaccine only to eligible children. Condition For five (or 83%) of six providers selected for testing, CHCC was unable to provide the Site Visit Reports to verify that the required information of vaccination records was maintained by each service provider. Cause: CHCC was unable to provide the supporting documents as it was lost during the transition to the new management and their current control and procedures are not suitably designed to properly maintain and retain all the documents. Effect: The CHCC is in noncompliance with the applicable Special Tests and Provisions – Record of Immunization. Recommendation: CHCC should improve their record-keeping policies and controls, such as duplication of documents into a soft copy, to ensure that a seamless transition is achieved whenever changes to management take into effect. Views of Responsible Officials: CHCC partially concurs with the finding. Since 2020, the CHCC has conducted the following steps to ensure that annual site visits for VFC providers are completed and documented appropriately to evaluate adherence to the VFC program requirements: - Worked with CDC Subject Matter Experts to ensure that data systems for site visit findings/reporting were accessible to the VFC Coordinator. Training on the system was also provided to the VFC Coordinator. This system is cloud based and accessible to anyone provided access. Therefore, should staff turnover occur, access to prior reports and the system for submitting new site visit reports will continue to be accessible to the organization and to team members who will take on the responsibility. - Ensure that Position Descriptions for the VFC Coordinator clearly specify responsibilities for implementing the VFC Program in accordance with the Immunization Program Operating Manual (IPOM), which outlines the requirements for annual provider compliance site visits, including the sampling of patient records to verify eligibility screening and administration of VFC vaccine only to eligible children. - Provided training/refresher to the staff member assigned/responsible (VFC Coordinator) for conducting site visits - Timeliness and completeness of site visit entries have been incorporated as part of the program’s activity workplan.
Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases Award Number: 1NU50CK0004990100 and 6NU50CK0004990104 Area: Equipment and Real Property Management Questioned Costs: Undeterminable Criteria: In accordance with 2 CFR 200.313(b), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and regulations. The CHCC Operating Policy: Fixed Asset/Property Changes requires the CHCC Property Management Branch to perform an annual physical inventory of all fixed assets/property and to document and control all changes in fixed assets/property. Further, in accordance with 2 CFR 200.313(d)(1), property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. Lastly, 2 CFR 200.313(d)(3) requires that adequate maintenance procedures must be developed to keep the property in good condition. Condition: For eight (or 100%) of eight capital assets selected for testing, the following were noted: 1. CHCC did not provide any supporting documentation that a physical inventory count was performed in FY2020. No questioned costs are presented as we are not able to quantify the extent of noncompliance. 2. CHCC’s capital assets listing does include all the required information for equipment and real property that is in accordance with 2 CFR 200.313(d)(1). No questioned costs are presented as we are not able to quantify the extent of noncompliance. 3. Capital asset items could not be traced to the results of the periodic maintenance procedures performed. No questioned costs are presented as we are not able to quantify the extent of noncompliance Cause: 1. CHCC’s current policy and procedure for capital asset listing management and maintenance are not in accordance with the federal requirements stated in 2 CFR 200.313(d)(1). 2. CHCC’s document maintenance and retention controls did not operate as designed to ensure that the recorded results of the physical inventory and maintenance procedures are stored properly and that documents are easily retrieved. 3. The results of CHCC’s periodic maintenance procedures lack unique identifiers necessary to trace the selected samples between the capital assets listing and the maintenance results. Effect: CHCC is in noncompliance with applicable Equipment and Real Property Management requirements. Questioned costs are undetermined as we are unable to quantify the extent of noncompliance. Recommendation: 1. CHCC should update the structure and contents of their current capital asset listing to include all the information required by 2 CFR 200.313(d)(1). Additionally, CHCC should improve their policies and procedures on management and maintenance of their capital asset listing. 2. CHCC should implement more stringent policies and procedures in relation to their document maintenance and retention to ensure that documents are easily retrieved and provided in a timely manner. Views of Responsible Officials: CHCC concurs with the findings. CHCC will update its Capital Assets policy to comply with the requirements of 2 CFR 200.313. Furthermore, CHCC will ensure that there is a clear crosswalk between the Preventive Maintenance Record with our Facilities Department and the Capital Assets listing that is revised pursuant to the requirements of 2 CFR 200.313. CHCC would like to clarify that although the documentation fell short of the Uniform Guidance documentation, all the physical existence and working conditions were verifiable during the audit.
Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases Award Number: 6-NU50CK000499-01-04, 6-NU50CK000499-01-05 and 5-NU50CK000499-02-00 Area: Reporting Questioned Costs: $ -0- Criteria: In accordance with the applicable reporting requirements stated in the grant agreements, monthly fiscal reports are required to be submitted for non-expired or non-terminated grants. Condition: For eight (or 100%) of eight monthly fiscal reports selected for testing, CHCC did not provide copies of the fiscal reports for inspection by the audit team. Cause: CHCC lacks controls or procedures that allows them to properly maintain submitted reports and extract copies on a timely manner. Effect: CHCC is in noncompliance with applicable reporting requirements but no questioned cost result as the finding is non-monetary in nature. Recommendation: CHCC should establish a more stringent document retention policies and procedures, such as creating backup copies or maintaining a server that contains all the submitted reports to allow them to retrieve documents on a timely manner. Views of Responsible Officials: CHCC agrees with the findings and will establish a stringent records retention policy, even for reports that were electronically completed and submitted using Grantor portals. These fiscal reports were done on the RedCap before 2023 and were readily accessible, hence ELC Program Staff did not maintain separate offline copies of the reports. When ELC transitioned to ELC CAMP, CHCC lost access to the submitted and saved reports. Hence, CHCC cannot provide supporting documents to its assertion that all reports were submitted.
Federal Agency: U.S. Department of Health and Human Resources CFDA Program: 93.870 Maternal, Infant and Early Childhood Home Visting Grant Program Award Number: X10MC32212 Area: Procurement and Suspension and Debarment Questioned Costs: $37,473 Criteria: In accordance with 2 CFR 180.300, entities that enter into covered transactions must verify that the person with whom they intend to do business is not excluded or disqualified by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, according to 2 CFR 180.220(b)(1), a procurement transaction is considered a covered transaction if the contract amount is expected or to equal or exceed $25,000. Condition: CHCC did not verify whether a person or a vendor is excluded or disqualified pursuant to the requirements of 2 CFR 180.300 prior to entering into the following covered transactions that exceeded the $25,000 threshold. Cause: CHCC’s current policy or procedure for suspension and debarment monitoring only applies to newly contracted persons or vendors under a covered transaction, thus not pursuant to the requirements or provisions of 2 CFR 180.300. Effect: CHCC is in noncompliance with applicable Suspension and Debarment regulations and questioned cost of $37,473 result. Recommendation: CHCC should revise or update their policies and procedures for monitoring suspension and debarment status of each vendor of covered transactions. These should be reflective of the requirements set by 2 CFR 180.300. Views of Responsible Officials: CHCC concurs with the findings but not the questioned costs. CHCC Division Grants and Financial Integrity (DGFI), updated our Suspension and Debarment procedure to comply with 2 CFR 180.300. To address the question cost of $37,473, CHCC imported from SAM.gov the Exclusion reports dated April 2020 and October 2020 and confirmed that none of the vendors cited in this finding are in the list of excluded vendors. Auditor Response: In accordance with 2 CFR 2900.3(a), a questioned cost is defined as a possible violation of statute, regulation, or the terms and conditions of a Federal award. The current process of CHCC monitoring suspension and debarment status of each vendor or supplier under a covered transaction is not designed to be in accordance with the provisions stated in 2 CFR 180.300 which is the statute to be followed as identified in the terms and conditions of the federal awards. As such, we retain the questioned costs.