Audit 404205

Federal Agency: United States Department of Health and Human Services Federal Program Name: FVPSA American Rescue Plan COVID-19 Testing, Vaccines, and Mobile Health Units Supplemental Funding Assistance Listing Number: 93.592 Federal Award Identification Number and Year: 90EV0540-01-C6 - 2021 Award Period: March 15, 2021 through September 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance – Suspension and Debarment • Other Matter – Noncompliance with Suspension and Debarment Compliance Requirements Criteria or Specific Requirement: Uniform Guidance §200.214 requires non‑Federal entities to verify that parties involved in covered transactions are not suspended, debarred, or otherwise excluded from participation in federal assistance programs prior to entering into the transaction. Verification may be achieved by reviewing the System for Award Management (SAM.gov) exclusions, obtaining a certification from the vendor, or including a suspension and debarment representation within the contract. Documentation of the verification performed is required to demonstrate compliance. Condition: National Indigenous Women’s Resource Center (the Center) did not retain sufficient documentation to demonstrate that a required suspension and debarment review was completed for one of six contractors selected for testing. As a result, the Center was unable to evidence that this contractor was verified as neither suspended nor debarred prior to contract execution. Questioned Costs: None Context: Of the 19 contractors, a total of six contractors were selected for testing. Out of the six sampled, the Center was unable to evidence that was verified as neither suspended nor debarred for one contractor prior to contract execution.Cause: Management stated that the employee previously responsible for performing and retaining suspension and debarment checks is no longer employed by the organization. Management further explained that any documentation evidencing completion of the check, if it existed, may have been stored on the former employee’s device, which was subsequently wiped in accordance with IT security procedures. Consequently, management is unable to substantiate that the suspension and debarment check was performed, as no documentary evidence is available to support its completion. Effect: Without evidence of suspension and debarment verification prior to contract execution, the Center is not able to demonstrate compliance with federal requirements. This increases the risk that federal funds could be awarded to vendors that are suspended or debarred from participation in federal programs. Repeat Finding: No Recommendation: CLA recommends management establish and document controls to verify and retain evidence of suspension and debarment checks for all covered transactions prior to contract execution, including maintaining documentation in a centralized and accessible location. Views of Responsible Officials: Please see the attached Management’s Corrective Action Plan.