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
FINDING 2022-005 Subject: Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) - Suspension and Debarment Federal Agency: Department of Health and Human Services Federal Program: Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) Assistance Listings Number: 93.104 Federal Award Number and Year (or Other Identifying Number): 1H79SM082981-01 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 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) funds, recipients are required to verify that 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 (e.g., grant agreement) that are expected to equal or exceed $25,000 and all subawards. The verification is to be done by checking the SAM exclusions list, collection of a certification from that person or entity, or adding a clause or condition to the covered transaction with that person or entity. INDIANA STATE BOARD OF ACCOUNTS 24 ELKHART COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Upon inquiring of the County to determine its policies and procedures related to suspension and debarment requirements for the Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) funds, the County stated procedures were not in place to ensure vendors were not suspended or debarred prior to entering into covered transactions. One covered transaction for funds passed through to a subrecipient was identified during the audit period. The amount passed through to the subrecipient was $914,863. The identified transaction was examined to determine if the County verified the suspension and debarment status of the subrecipient prior to payment. Upon review, we determined that the County entered into a memorandum of understanding (MOU) with the subrecipient on June 22, 2020. However, the County had not performed procedures to ensure the subrecipient was not suspended or debarred, or otherwise excluded or disqualified, from participation in federal assistance programs or activities at the time of the initial MOU or at any time during the audit period. 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. 2 CFR 180.300 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 SAM Exclusions; 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." INDIANA STATE BOARD OF ACCOUNTS 25 ELKHART COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the County to ensure vendors were not suspended or debarred, or otherwise excluded, from participation in federal awards. 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, a subrecipient to whom payments were made was 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.
Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 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: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor list. Views of responsible officials: There is no disagreement with the audit finding.
Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 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: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor list. Views of responsible officials: There is no disagreement with the audit finding.
Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Pass-Through Agency: n/a Pass-Through Number(s): n/a Award Period: 6/1/21-5/31/22 & 6/1/22-5/31/23 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria or specific requirement: § 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: The Organization could not provide documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Questioned costs: $133,105 Context: Two of two vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Management turnover Effect: The Organization could enter into transactions using federal dollars with vendors that are suspended or debarred. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-006. Recommendation: We recommend that the Organization verify that vendors are not suspended or debarred prior to signing contracts or create an approved vendor list. Views of responsible officials: There is no disagreement with the audit finding.
Criteria: The Corporation must maintain and adhere to documented procurement procedures that must conform to the procurement standards in 2 CFR Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement. Additionally, in accordance with 2 CFR Section 200.214, the Corporation must verify that vendors are not suspended or debarred from participating in Federal funds. Condition: We noted that there was a lack of evidence that policies and procedures were applied as required under the noted 2 CFR Sections in “Criteria”. Cause: The Corporation did not maintain formal documentation or evidence to support that a competitive price analysis for vendors or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Effect or Potential Effect: We were unable to determine whether charges relating to vendor services or goods charged to the Federal programs are in accordance with 2 CFR Sections 200.317 through 200.327 or 200.214. Questioned costs: None Context: The Corporation was unable to provide evidence of procurement, suspension or debarment verification performed for walkthrough purposes or any samples that would be selected. Additionally, per management, no written documentation can be provided for any sole source procurements. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2021-010 in the 2021 report. Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating procurement, required price analysis of vendors, and suspension and debarment verifications. View of Responsible Officials: Due to turnover of several key financial executives and personnel and lack of formal documentation of current policies and procedures, the Corporation was unable to provide evidence of procurement, suspension or debarment verification performed as of December 31, 2022.
Criteria: The Corporation must maintain and adhere to documented procurement procedures that must conform to the procurement standards in 2 CFR Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement. Additionally, in accordance with 2 CFR Section 200.214, the Corporation must verify that vendors are not suspended or debarred from participating in Federal funds. Condition: We noted that there was a lack of evidence that policies and procedures were applied as required under the noted 2 CFR Sections in “Criteria”. Cause: The Corporation did not maintain formal documentation or evidence to support that a competitive price analysis for vendors or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Effect or Potential Effect: We were unable to determine whether charges relating to vendor services or goods charged to the Federal programs are in accordance with 2 CFR Sections 200.317 through 200.327 or 200.214. Questioned costs: None Context: The Corporation was unable to provide evidence of procurement, suspension or debarment verification performed for walkthrough purposes or any samples that would be selected. Additionally, per management, no written documentation can be provided for any sole source procurements. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2021-010 in the 2021 report. Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating procurement, required price analysis of vendors, and suspension and debarment verifications. View of Responsible Officials: Due to turnover of several key financial executives and personnel and lack of formal documentation of current policies and procedures, the Corporation was unable to provide evidence of procurement, suspension or debarment verification performed as of December 31, 2022.
Criteria: The Corporation must maintain and adhere to documented procurement procedures that must conform to the procurement standards in 2 CFR Sections 200.317 through 200.327. These sections include policies and procedures related to competition, informal and formal procurement methods and noncompetitive procurement. Additionally, in accordance with 2 CFR Section 200.214, the Corporation must verify that vendors are not suspended or debarred from participating in Federal funds. Condition: We noted that there was a lack of evidence that policies and procedures were applied as required under the noted 2 CFR Sections in “Criteria”. Cause: The Corporation did not maintain formal documentation or evidence to support that a competitive price analysis for vendors or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Effect or Potential Effect: We were unable to determine whether charges relating to vendor services or goods charged to the Federal programs are in accordance with 2 CFR Sections 200.317 through 200.327 or 200.214. Questioned costs: None Context: The Corporation was unable to provide evidence of procurement, suspension or debarment verification performed for walkthrough purposes or any samples that would be selected. Additionally, per management, no written documentation can be provided for any sole source procurements. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2021-010 in the 2021 report. Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating procurement, required price analysis of vendors, and suspension and debarment verifications. View of Responsible Officials: Due to turnover of several key financial executives and personnel and lack of formal documentation of current policies and procedures, the Corporation was unable to provide evidence of procurement, suspension or debarment verification performed as of December 31, 2022.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.
U.S. Department of Treasury COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - 21.027 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: For vendor contracts, suspension and debarment checks were not performed. Questioned Costs - None noted. Context: For 21.027, there were 15 vendors receiving a total of $1,382,977 subject to suspension and debarment requirements. Of those 15, a sample of 3 vendors receiving a total of $324,205 were selected for testing and none of the three were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated three vendors selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: 2021-002 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: Expenditures for these programs were identified after many of these purchases had taken place. Departments performing their own procurement processes may not have been familiar with federal requirements or known at the time of purchase that this would be reimbursed with federal funds and did not complete the required suspension and debarment checks. Recommendation: We recommend that the Unified Government communicate to all departments that purchases using federal funds have suspension and debarment checks completed prior to purchase and the procurement department provide training on the requirements to properly document that suspension and debarment checks are completed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.
U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs - None noted. Context: For 14.231, there were seven subrecipients receiving a total of $1,013,942 subject to suspension and debarment requirements. Of those seven, a sample of two subrecipients receiving a total of $469,455 were selected for testing and none of the two were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated two subrecipients selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.
U.S. Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs - None noted. Context: For 14.231, there were seven subrecipients receiving a total of $1,013,942 subject to suspension and debarment requirements. Of those seven, a sample of two subrecipients receiving a total of $469,455 were selected for testing and none of the two were verified by the Unified Government for Suspension and Debarment. A subsequent check was completed and none of the associated two subrecipients selected for testing were suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step.
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 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: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 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: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 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: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 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: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 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: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 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: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2022-002 ? Procurement and Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Centers Cluster and Health Center Infrastructure Support Assistance Listing Number: 93.224 and 93.527; 93.526 Federal Award Identification Number: H8FCS40647-01; C8ECS44753-01 Award Periods: April 1, 2021 ? March 31, 2023; September 15, 2021 ? September 14, 2024, respectively Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: ? 200.320 Methods of procurement to be followed: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. ? 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: The organization did not maintain proper documentation for 1) determining the rationale of the sole-source procurement methodology that it applied and 2) that suspension and debarment was checked quarterly per the Organization's policy for vendors reimbursed by the federal grant. Questioned Costs: None. Context: Two (2) of two (2) procurement transactions; Two (2) of two (2) suspension and debarment transactions Cause: The organization did not document its rationale for choosing the noncompetitive procurement method or its quarterly review of suspension and debarment of vendors. Effect: The Organization may inadvertently select vendors without regard to fair competition and cost analysis or vendors that may be federally suspended and disbarred. Repeat Finding: No. Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Views of Responsible Officials: There is no disagreement with the audit finding.