Finding Text
Finding 2023.002: Procurement, Suspension and Debarment - Material Weakness
Grantor: U.S. Department of Health and Human Services
Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 - Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program, COVID-19 - Grants for New and Expanded Services under the Health Center Program
Federal Assistance Listing Numbers: 93.224 and 93.527
Criteria
In accordance with §200.318(a), General Procurement Standards, a non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement.
In addition, in accordance with §200.213 and §180.300, 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.
Condition
There was no evidence that the Organization reviewed vendors for suspension and debarment in accordance with Uniform Guidance requirements.
Cause
The Organization did not have adequate controls to illustrate review of vendors for any suspensions or debarment.
Effect or Potential Effect
The Organization may procure goods and services from vendors that have been suspended or debarred from doing business with the Federal government.
Questioned Costs
None.
Context
We selected a sample of 6 vendors for suspension and debarment testing. For all 6 vendors tested, management did not provide adequate supporting documentation to support that the vendors were not suspended or debarred.
Identification of Repeat Finding
Not a repeat finding.
Recommendation
The Organization should develop a written procedure to review all vendors in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement.
Views of Responsible Officials and Planned Corrective Actions
Management and the Board of Directors agree with the finding and will implement additional controls to ensure vendors are being reviewed for suspension and debarment and there is evidence of a formal review being performed.