Finding Text
Finding 2022-003 – Suspension & Debarment
Federal program and specific federal award
U.S. Department of Health and Human Services (HHS)
93.224 Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program)
Type of Finding: Significant deficiency in internal control over compliance
Specific requirement-criteria
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.
The Association did not verify that certain employees and vendors were not suspended, debarred, or
otherwise excluded from or ineligible for participation in federal programs or activities before entering
into transactions with them. The condition affected four of four parties selected for testing. The
Organization did ultimately verify that the contracted parties were not suspended or debarred; however, it
was after initially contracting with them.
Cause
Due to open positions in the finance department, oversight and communication regarding following the Association’s suspension and debarment process was not followed. During 2022, the Associated hired contract financial consultants to aid in the open positions and bring financial information and process up to date.
Effect
Ineligible parties could possibly participate in and be reimbursed by a federal program through the Association.
Questioned Costs
None.
Repeat finding
No.