Finding 2022-003 ? Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Grants for New and Expanded Services Under the Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: L1CCS39368-01-00; L2CCS42352-01-00 Award Periods: July 1, 2020 ? June 30, 2021; July 1, 2021 ? June 30, 2023 respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Legacy did not document that Sam.gov was checked prior to entering into a contract with a vendor. Questioned Costs: None. Context: Two (2) of two (2) vendors tested. Cause: Legacy did not create and maintain documentation showing that suspension and debarment had be checked prior to engaging a vendor. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: We recommend that Legacy retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. The organization can keep screenshots that Sam.gov was checked or a PDF print out of the web page. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-003 ? Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Grants for New and Expanded Services Under the Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: L1CCS39368-01-00; L2CCS42352-01-00 Award Periods: July 1, 2020 ? June 30, 2021; July 1, 2021 ? June 30, 2023 respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Legacy did not document that Sam.gov was checked prior to entering into a contract with a vendor. Questioned Costs: None. Context: Two (2) of two (2) vendors tested. Cause: Legacy did not create and maintain documentation showing that suspension and debarment had be checked prior to engaging a vendor. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: We recommend that Legacy retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. The organization can keep screenshots that Sam.gov was checked or a PDF print out of the web page. Views of Responsible Officials: There is no disagreement with the audit finding.
2021-006 Compliance with Uniform Guidance - Procurement; Information on Federal Program: Unaccompanied Alien Children (Assistance Listing No. 93.676) provided by the Department of Health and Human Services.; Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs.; Condition: During our testing for procurement compliance, it was determined that the Agency did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs.; Questioned Cost: None; Cause: The Agency was not aware of the requirement to review an entity’s status.; Effect: The Agency is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Agency could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs.; Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation.; Repeat Finding: Yes; Recommendation: We recommend the Agency develop a purchasing policy which encompasses the requirements of the Uniform Guidance, including the requirement to review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs.; Views of the Responsible Officials and Planned Corrective Actions: The Agency’s management agrees with this finding and during the 21/22 fiscal year the Payables Accountant (Jarri Melton) completed a review of the Agency’s vendor list to ensure that the Agency was in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. A hard copy of this review was signed off by the Payables Accountant (Jarri Melton) and the CFO (Jeni Rodriguez), then filed. The Payables Accountant (Jarri Melton) and the CFO (Jeni Rodriguez) will perform this review going forward for any new vendors. Additionally, the Agency’s purchasing policy was updated in fiscal year 21-22, with purchase orders, a purchase order numbering system and tracking. There are monthly closings / reconciling of outstanding purchase orders from the prior month done by the Payables Accountant (Jarri Melton). The Revenue Accountant (Valerie Myers) or the Managed Care Liaison (Ms. Gray McCaffrey) are the team that are able to assign purchase order numbers to the purchase orders and the originals are kept in a folder for the Payables Accountant (Jarri Melton) to retrieve when closing out the month.
2021-006 Compliance with Uniform Guidance - Procurement; Information on Federal Program: Unaccompanied Alien Children (Assistance Listing No. 93.676) provided by the Department of Health and Human Services.; Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs.; Condition: During our testing for procurement compliance, it was determined that the Agency did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs.; Questioned Cost: None; Cause: The Agency was not aware of the requirement to review an entity’s status.; Effect: The Agency is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Agency could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs.; Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation.; Repeat Finding: Yes; Recommendation: We recommend the Agency develop a purchasing policy which encompasses the requirements of the Uniform Guidance, including the requirement to review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs.; Views of the Responsible Officials and Planned Corrective Actions: The Agency’s management agrees with this finding and during the 21/22 fiscal year the Payables Accountant (Jarri Melton) completed a review of the Agency’s vendor list to ensure that the Agency was in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. A hard copy of this review was signed off by the Payables Accountant (Jarri Melton) and the CFO (Jeni Rodriguez), then filed. The Payables Accountant (Jarri Melton) and the CFO (Jeni Rodriguez) will perform this review going forward for any new vendors. Additionally, the Agency’s purchasing policy was updated in fiscal year 21-22, with purchase orders, a purchase order numbering system and tracking. There are monthly closings / reconciling of outstanding purchase orders from the prior month done by the Payables Accountant (Jarri Melton). The Revenue Accountant (Valerie Myers) or the Managed Care Liaison (Ms. Gray McCaffrey) are the team that are able to assign purchase order numbers to the purchase orders and the originals are kept in a folder for the Payables Accountant (Jarri Melton) to retrieve when closing out the month.
2021-006 Compliance with Uniform Guidance - Procurement; Information on Federal Program: Unaccompanied Alien Children (Assistance Listing No. 93.676) provided by the Department of Health and Human Services.; Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs.; Condition: During our testing for procurement compliance, it was determined that the Agency did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs.; Questioned Cost: None; Cause: The Agency was not aware of the requirement to review an entity’s status.; Effect: The Agency is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Agency could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs.; Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation.; Repeat Finding: Yes; Recommendation: We recommend the Agency develop a purchasing policy which encompasses the requirements of the Uniform Guidance, including the requirement to review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs.; Views of the Responsible Officials and Planned Corrective Actions: The Agency’s management agrees with this finding and during the 21/22 fiscal year the Payables Accountant (Jarri Melton) completed a review of the Agency’s vendor list to ensure that the Agency was in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. A hard copy of this review was signed off by the Payables Accountant (Jarri Melton) and the CFO (Jeni Rodriguez), then filed. The Payables Accountant (Jarri Melton) and the CFO (Jeni Rodriguez) will perform this review going forward for any new vendors. Additionally, the Agency’s purchasing policy was updated in fiscal year 21-22, with purchase orders, a purchase order numbering system and tracking. There are monthly closings / reconciling of outstanding purchase orders from the prior month done by the Payables Accountant (Jarri Melton). The Revenue Accountant (Valerie Myers) or the Managed Care Liaison (Ms. Gray McCaffrey) are the team that are able to assign purchase order numbers to the purchase orders and the originals are kept in a folder for the Payables Accountant (Jarri Melton) to retrieve when closing out the month.
2021-006 Compliance with Uniform Guidance - Procurement; Information on Federal Program: Unaccompanied Alien Children (Assistance Listing No. 93.676) provided by the Department of Health and Human Services.; Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs.; Condition: During our testing for procurement compliance, it was determined that the Agency did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs.; Questioned Cost: None; Cause: The Agency was not aware of the requirement to review an entity’s status.; Effect: The Agency is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Agency could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs.; Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation.; Repeat Finding: Yes; Recommendation: We recommend the Agency develop a purchasing policy which encompasses the requirements of the Uniform Guidance, including the requirement to review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs.; Views of the Responsible Officials and Planned Corrective Actions: The Agency’s management agrees with this finding and during the 21/22 fiscal year the Payables Accountant (Jarri Melton) completed a review of the Agency’s vendor list to ensure that the Agency was in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. A hard copy of this review was signed off by the Payables Accountant (Jarri Melton) and the CFO (Jeni Rodriguez), then filed. The Payables Accountant (Jarri Melton) and the CFO (Jeni Rodriguez) will perform this review going forward for any new vendors. Additionally, the Agency’s purchasing policy was updated in fiscal year 21-22, with purchase orders, a purchase order numbering system and tracking. There are monthly closings / reconciling of outstanding purchase orders from the prior month done by the Payables Accountant (Jarri Melton). The Revenue Accountant (Valerie Myers) or the Managed Care Liaison (Ms. Gray McCaffrey) are the team that are able to assign purchase order numbers to the purchase orders and the originals are kept in a folder for the Payables Accountant (Jarri Melton) to retrieve when closing out the month.