Finding 2022-001: Suspension/Disbarment Searches Assistance listing number and name: 19.040 ? Public Diplomacy Programs 19.900 - AEECA/ESF PD Programs Year: 2022 Federal agency: U.S. Department of State Criteria: Per 2 CFR section 200.214, non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180, which 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. 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. Condition and context: During our audit, we noted that IWPR did not perform timely, the search whether vendors were suspended or debarred, prior to payments. The searches were ultimately performed in 2023 but not during the procurement process in 2022 as required by the internal policy that vetting should be carried out prior to the procurement. This was rectified by performing ?post dated? vetting which confirmed IWPR did not support suspended or debarred parties. Cause: IWRP was aware of the requirement but due to turnover in the staff, this was not performed in timely manner. Effect: Vendors used could have been used for services performed as part of the federal award whilst suspended or disbarred. No vendors used were suspended or disbarred and thus there are no questioned costs. Repeat finding: No. Questioned costs: None noted. Recommendation: We recommend that management reviews periodically, if there is staff turnover, that the searches as part of its initial procurement processes and controls and retain documentation for each vendor. Views of responsible officials and planned corrective actions: Management acknowledges the finding and has implemented correction actions. See corrective action plan.
Finding 2022-001: Suspension/Disbarment Searches Assistance listing number and name: 19.040 ? Public Diplomacy Programs 19.900 - AEECA/ESF PD Programs Year: 2022 Federal agency: U.S. Department of State Criteria: Per 2 CFR section 200.214, non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180, which 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. 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. Condition and context: During our audit, we noted that IWPR did not perform timely, the search whether vendors were suspended or debarred, prior to payments. The searches were ultimately performed in 2023 but not during the procurement process in 2022 as required by the internal policy that vetting should be carried out prior to the procurement. This was rectified by performing ?post dated? vetting which confirmed IWPR did not support suspended or debarred parties. Cause: IWRP was aware of the requirement but due to turnover in the staff, this was not performed in timely manner. Effect: Vendors used could have been used for services performed as part of the federal award whilst suspended or disbarred. No vendors used were suspended or disbarred and thus there are no questioned costs. Repeat finding: No. Questioned costs: None noted. Recommendation: We recommend that management reviews periodically, if there is staff turnover, that the searches as part of its initial procurement processes and controls and retain documentation for each vendor. Views of responsible officials and planned corrective actions: Management acknowledges the finding and has implemented correction actions. See corrective action plan.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Health Center to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. The Health Center should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred, and retain documentation to support those procedures are being followed. Condition: During our testing, we noted the Health Center was not able to provide documentation to support that policies or procedures in place had been followed to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of three disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Health Center did not have documentation available to support there was a check of the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred. The vendor selected was compared to the SAM Exclusions at the time of testing and was noted to not be suspended or disbarred, although the testing could not be performed back to the date of the transaction. Cause: The Health Center either did not follow policies and procedures under the procurement policy related to suspension or debarment, or did not retain support of control procedures being performed. Effect: The lack of documentation or control over the formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number 2021-003 was a significant deficiency. Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Views of responsible officials: There is no disagreement with the audit finding. Policy and procedures were put in place late in 2022 in response to the prior year audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Health Center to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. The Health Center should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred, and retain documentation to support those procedures are being followed. Condition: During our testing, we noted the Health Center was not able to provide documentation to support that policies or procedures in place had been followed to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of three disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Health Center did not have documentation available to support there was a check of the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred. The vendor selected was compared to the SAM Exclusions at the time of testing and was noted to not be suspended or disbarred, although the testing could not be performed back to the date of the transaction. Cause: The Health Center either did not follow policies and procedures under the procurement policy related to suspension or debarment, or did not retain support of control procedures being performed. Effect: The lack of documentation or control over the formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number 2021-003 was a significant deficiency. Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Views of responsible officials: There is no disagreement with the audit finding. Policy and procedures were put in place late in 2022 in response to the prior year audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Health Center to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. The Health Center should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred, and retain documentation to support those procedures are being followed. Condition: During our testing, we noted the Health Center was not able to provide documentation to support that policies or procedures in place had been followed to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of three disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Health Center did not have documentation available to support there was a check of the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred. The vendor selected was compared to the SAM Exclusions at the time of testing and was noted to not be suspended or disbarred, although the testing could not be performed back to the date of the transaction. Cause: The Health Center either did not follow policies and procedures under the procurement policy related to suspension or debarment, or did not retain support of control procedures being performed. Effect: The lack of documentation or control over the formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number 2021-003 was a significant deficiency. Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Views of responsible officials: There is no disagreement with the audit finding. Policy and procedures were put in place late in 2022 in response to the prior year audit finding.
Federal Agency: U.S. Department of the Treasury Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Period: 3/3/2021 ? 12/31/2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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. Condition: The City did not maintain documentation to support that the required search for suspension and debarment was performed. Questioned Costs: None Context: While performing audit procedures, it was noted that City management did not maintain documentation that a search for suspension and debarment prior to finalizing the procurement was performed. Cause: The City did not have a procedure in place to require documentation be maintained that a search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No Recommendation: We recommend that the City review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding No. 2022-004: Procurement Policy ? Material Weakness in Internal Control Over Financial Reporting; U.S. Department of Health and Human Services, Rare Disorders: Research, Surveillance, Health Promotion, and Education; Assistance Listing Number 93.315 Condition There is no evidence of a documented formal procurement policy with regards to federal grant awards and expenditures, no documented support that a competitive price analysis for vendors and organizations funded with federal grant funds were performed and no evidence that suspension and debarment verifications were performed for certain vendors and organizations, as required by the general procurement standards of the Uniform Guidance. Context We selected four samples which were deemed sole sourced by management and noted no written documentation for this conclusion or evidence of suspension or debarment verification being performed was maintained in the file. Based on our discussions with management, they were not aware of the Uniform Guidance requirements with regards to procurement. Criteria Under the Uniform Guidance Section 200.318, General Procurement Standards, a non-Federal entity must have and use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement also known as sole source. Under Uniform Guidance Section 200.214, Suspension and Debarment, and 2 CFR Part 180, non-federal entities are required to verify that vendors are not suspended or debarred from participating in federal funds. Cause Management stated it was not aware of the Uniform Guidance requirements with regards to procurement and, therefore, did not develop a procurement policy that includes the provisions of the general procurement standards required under the Uniform Guidance. Effect Charges relating to vendor services and sub-awards that were charged to the federal award may not be in accordance with the specific compliance requirements of the Uniform Guidance. Questioned Costs $97,078, representing total sub-awards and consulting expenses paid during the year. Repeat Finding No. Recommendation We recommend that the Association establish a written procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. We also recommend that a review of all existing vendor or sub-awardee contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Views of Responsible Officials and Planned Corrective Action See corrective action plan.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Federal Agency: U.S. Department of Agriculture Federal Program Title: Supplemental Nutrition Assistance Program CFDA Number: 10.561 Award Period: December 1, 2019 through September 30, 2023 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318(a) states, ?the non-Federal entity must have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward.? In addition, per the Code of Federal Regulations 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations. The regulations 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: During our testing, we noted the Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. Questioned Costs: None Cause: Procurement policies and procedures were not adopted by the Organization. Effect: The Organization may not have received a competitive bid for services, and may have engaged a suspended or debarred contractor. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Organization implement necessary internal controls to ensure a competitive bid process is performed, and all vendors are reviewed for suspension and debarment, prior to entering into contracts utilizing federal awards. These internal controls should also include a conflict-of-interest clause with all vendors within contract language. Views of responsible officials: Management agrees with the finding.
2022-003 Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds CFDA Number: 21.027 Award Period: June 23, 2022 through June 22, 2023 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318(a) states, ?the non-Federal entity must have and use document procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward.? In addition, per the Code of Federal Regulations 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations. The regulations 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: During our testing, we noted the Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. Questioned Costs: None Cause: Procurement policies and procedures were not adopted by the Organization. Effect: The Organization may not have received a competitive bid for services, and may have engaged a suspended or debarred contractor. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Organization implement necessary internal controls to ensure a competitive bid process is performed, and all vendors are reviewed for suspension and debarment, prior to entering into contracts utilizing federal awards. These internal controls should also include a conflict-of-interest clause with all vendors within contract language. Views of responsible officials: Management agrees with the finding.
FINDING 2022-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2022 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The County elected to receive the standard revenue loss allowance, allowing the County to claim its total State and Local Fiscal Recovery Funds (SLFRF) allocation of $4,681,531 as revenue loss to use for government services. As such, all SLFRF program funds were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contracts and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements related to covered transactions. Upon inquiry of the County in order to review the procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the County divulged that they were unaware of the suspension and debarment requirements related to the SLFRF awards. A population of three covered transactions for goods or services that equaled or exceeded $25,000 paid from SLFRF funds during the audit period were identified. The three contracts totaled $3,103,878, with payments totaling $1,289,929 during 2022. The County did not verify the vendors' suspension and debarment status prior to payment due to the County not having any policies or procedures in place to verify that contractors were neither suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "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 200.214 states: "Non-federal entities and contractors are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (c) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed or implemented, which includes segregation of key functions, by management of the County to ensure that policies and procedures were in place related to suspension and debarment. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls and develop policies and procedures to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 2022 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The County elected to receive the standard revenue loss allowance, allowing the County to claim up to $10 million of its total State and Local Fiscal Recovery Funds (SLFRF) allocation of $16,273,089 as revenue loss to use for government services. During 2022, the County expended SLFRF award funds in the following categories: Public Health, Revenue Loss, and Infrastructure. The U.S. Department of the Treasury determined there are no subawards under the Revenue Loss eligible use category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships given there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The County did not have any policies or procedures in place related to the SLFRF suspension and debarment requirements. A population of nine vendors paid from SLFRF funds during the audit period were identified that had transactions which equaled or exceeded $25,000. Three vendors were selected for testing to verify if the County had verified if the vendor was suspended, debarred, or otherwise excluded, prior to entering in the covered transaction. One set of vendor transactions, in the amount of $805,530, was made for the mechanical upgrades to the Bartholomew County Jail. Although bids were obtained, the vendor's suspension and debarment was not verified prior to payment. The second transaction selected for testing in the amount of $44,808 was made for the purchase of a 2022 Chrysler Pacifica van. Several quotes were obtained and maintained; however, the purchase was ultimately made without verifying the vendor's suspension and debarment status. The third set of transactions tested in the amount $476,086 was for the Fairgrounds Water and Sewer project. Although bids were obtained, the suspension and debarment status was not verified prior to payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "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 200.214 states: "Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the County. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls and develop policies and procedures to ensure contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 2021 Pass-Through Entity: Direct Grant Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The City elected to receive the standard revenue loss allowance, allowing the City to claim $10,000,000 of its total State and Local Fiscal Recovery Funds (SLFRF) allocation of $16,549,045 as revenue loss to use for government services. All SLFRF program funds expended in 2022 were under the revenue loss eligible use category. The Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the City was only required to comply with suspension and debarment requirements related to contracts. The City's policies related to SLFRF suspension and debarment requirements included the Board of Public Works completing a review of each bid packet to ensure the bidder submitted a statement indicating if they were not suspended or debarred. Of the 13 transactions that equaled or exceeded $25,000 that were paid from SLFRF funds during the audit period, 2 were selected for testing to verify the City followed its procedures related to suspension and debarment. One transaction in the amount of $278,000 was made for the purchase of a street sweeper for the Street Department. Although bids were obtained for the street sweeper, the vendor's suspension and debarment status was not verified prior to payment. Documentation of the bids received was not presented to the Board of Public Works; therefore, the street sweeper was purchased without the appropriate approval from the City Board. The second transaction selected for testing in the amount of $65,823 was made for the purchase of a Dodge Ram truck for the Street Department. Several quotes were obtained; however, the purchase was ultimately made without verifying the vendor's suspension and debarment status. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "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 200.214 states: "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations . . . 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." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The system of internal controls as established by management of the City was not properly implemented to ensure that the policies and procedures in place related to suspension and debarment were appropriately followed. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of Federal statutes, regulations, and the terms and conditions of the Federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City establish a proper system of internal controls, including strengthening their policies and procedures to ensure their compliance with requirements related to suspension and debarment. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Suspension and Debarment (Material Weakness) Federal Agency: U.S. Treasury Pass-through Agency: N/A Cluster/Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Passed-through Identification: N/A Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the federal ward 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. In addition, under 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, 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), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The Town did not properly verify and document federal suspension and debarment status for one vendor prior to entering into a transaction with the vendor. Cause: The Town does not have formal policies and procedures in place to ensure vendors are not suspended or debarred. Effect: The Town’s system of internal controls was not designed effectively to prevent instances of noncompliance. However, it was determined that no vendor utilized was suspended or debarred. Questioned Costs: None Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Town implement policies and procedures to formally verify and document the suspension and debarment process for all entities that it enters into transactions with using federal funds. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
Finding 2022-006 Procurement, Suspension, and Debarment – Material Weakness. Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the nonfederal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with §200.317 through §200.327. In accordance with §200.214 non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. Condition: The Organization also has standard procurement procedures in place guiding purchasing decisions. However, due to need for expediency in choosing a contract that is partially funded by the federal award, the board of directors approved waiving the normal bidding process. The Organization also did not perform or document suspension and debarment checks on prospective vendors and subrecipients. Cause: The Organization’s personnel did not ensure to follow documented policies and procedures for selecting a contractor that were in compliance with the CFR 200. Additionally, the Organization did not have adequate internal controls in place to identify the need to ensure a check for suspended or debarred vendors on contractors occurred and was documented prior to entering into those agreements. Effect: Failure to maintain policies for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with federal regulations. This leads to the possibility that resources were purchased from vendors who were suspended and/or debarred. Questioned Costs: Unknown Repeat Finding: Not applicable as the Organization is a first time auditee. Recommendation: Standard forms should be updated to incorporate procurement and suspension and debarment criteria for both vendors and subrecipients. Controls should be implemented to ensure that the procurement decisions and suspension and debarment checks are reviewed by an appropriate member of management and are properly stored for future reference. Views of Responsible Official: See Corrective Action Plan.
FINDING 2022-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2022 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into subawards and covered transactions with the State and Local Fiscal Recovery Funds (SLFRF) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The County's policies related to SLFRF suspension and debarment requirements included the appropriate provisions for suspension and debarment be in the contract. Of the seven covered transactions, totaling $3,881,545, identified that were paid from SLFRF funds during the audit period, all seven were selected for testing to verify the County followed its procedures related to suspension and debarment. Of the seven covered transactions tested, three did not follow the County's procedures as outlined above. The three covered transactions, totaling $270,301, did not include the appropriate provisions in the contracts nor did the County require a certification or check the EPLS to ensure the entity was not suspended or debarred prior to making payment. The lack of internal controls and noncompliance were isolated to the transactions noted above. INDIANA STATE BOARD OF ACCOUNTS 19 JOHNSON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "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 200.214 Suspension and debarment states: "Non-federal entities and contractors are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The system of internal controls as established by management of the County was not properly implemented to ensure that the policies and procedures in place related to suspension and debarment were appropriately followed. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. INDIANA STATE BOARD OF ACCOUNTS 20 JOHNSON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls, including strengthening its policies and procedures to ensure its compliance with requirements related to suspension and debarment. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 21