Audit 405126

Finding 2025-001- Material Weakness related to Procurement and Suspension and Debarment Identification of the Federal Program Federal Agency: Department of Health and Human Services, Department of Homeland Security, Department of Defense, Department of Justice, National Science Foundation, Department of Agriculture, US Agency for International Development Program Name: Research and Development Cluster Assistance Listing Number: Various Criteria or Specific Requirement: 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR Section 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Medical Center did not evaluate all vendors for suspension and debarment during the fiscal year. As a result, there were instances of procurement transactions where the vendor was not subjected to suspension and debarment evaluation procedures prior to entering into the transaction. Cause: The issue occurred due to deficiencies in the design and operation of controls over the completeness and accuracy of vendor information provided to the third-party service provider for suspension and debarment monitoring. Specifically, controls were not in place to ensure that all vendors used for the Research and Development Cluster program expenditures were included in the vendor listing submitted for suspension and debarment monitoring. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements. Accordingly, the Medical Center could have entered into a procurement transaction with a suspended or debarred vendor. Questioned Costs: No questioned costs were identified. Context: Management was unable to provide evidence of a control being consistently performed throughout the audit period. The total population consisted of 1,374 vendors utilized for expenditures charged to the Research and Development Cluster. Our testing identified that 844 vendors, representing approximately $80 million in expenditures, were not evaluated for suspension and debarment prior to entering into a transaction. The remaining 530 vendors were appropriately evaluated. Subsequently, all 1,374 vendors were evaluated for suspension and debarment and none were noted as being suspended or debarred. Identification as a Repeat Finding: Not a repeat finding. Recommendation: Management should design and implement effective internal controls to ensure the completeness and accuracy of vendor listings submitted for suspension and debarment evaluation. Controls should include procedures to verify that all vendors associated with Federal program expenditures are evaluated prior to entering into transactions and that evaluation results are appropriately documented and monitored on an ongoing basis. Views of Responsible Officials: Management concurs with the finding and has implemented procedures to ensure the vendor list for suspension and debarment evaluation is complete and accurate.