Finding 1079894 (2022-009)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-10-22

AI Summary

  • Core Issue: The Organization has a significant deficiency in internal controls regarding compliance with vendor suspension and debarment policies.
  • Impacted Requirements: Failure to document compliance with 2 CFR part 180, which mandates checks against the federal exclusion list for vendors.
  • Recommended Follow-Up: Implement procedures to retain documentation proving vendor compliance with suspension and debarment policies.

Finding Text

Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 2/1/21 – 1/31/22, 2/1/22 – 1/31/23, 4/1/21 – 3/31/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Center to follow the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization had a proper policy around suspension and debarment, but was not able to provide documentation supporting the policy was followed for all vendors selected. Questioned costs: None. Context: In our testing covering three vendors, the Organization was not able to provide documentation supporting the Organization had followed its suspension and debarment policy. All vendors were checked against the exclusion list at the time of audit testing, and none were found to be suspended/debarred. Cause: Turnover in personnel at the Organization likely played a role, but the Organization was also focused on response to the COVID-19 pandemic at the time of vendor procurement. So timeliness was often most important in procuring vendors and related products/services. Effect: Without retaining documentation to support proper compliance with the Organization's policy, there is greater risk of noncompliance or inappropriate vendor selection. Recommendation: We recommend the Organization follow existing policy, but ensure procedures are in place to retain sufficient documentation to support review of vendors against federal exclusion list. View of responsible officials: No disagreement with the finding. Management will review procedures to ensure proper check of vendors is performed against federal exclusion list, and that documentation is maintained to support that review.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 503448 2022-005
    Significant Deficiency
  • 503449 2022-006
    Significant Deficiency
  • 503450 2022-007
    Significant Deficiency
  • 503451 2022-008
    Significant Deficiency
  • 503452 2022-009
    Significant Deficiency Repeat
  • 503453 2022-005
    Significant Deficiency
  • 503454 2022-006
    Significant Deficiency
  • 503455 2022-007
    Significant Deficiency
  • 503456 2022-008
    Significant Deficiency
  • 503457 2022-009
    Significant Deficiency Repeat
  • 503458 2022-005
    Significant Deficiency
  • 503459 2022-006
    Significant Deficiency
  • 503460 2022-007
    Significant Deficiency
  • 503461 2022-008
    Significant Deficiency
  • 503462 2022-009
    Significant Deficiency Repeat
  • 503463 2022-006
    Significant Deficiency
  • 1079890 2022-005
    Significant Deficiency
  • 1079891 2022-006
    Significant Deficiency
  • 1079892 2022-007
    Significant Deficiency
  • 1079893 2022-008
    Significant Deficiency
  • 1079895 2022-005
    Significant Deficiency
  • 1079896 2022-006
    Significant Deficiency
  • 1079897 2022-007
    Significant Deficiency
  • 1079898 2022-008
    Significant Deficiency
  • 1079899 2022-009
    Significant Deficiency Repeat
  • 1079900 2022-005
    Significant Deficiency
  • 1079901 2022-006
    Significant Deficiency
  • 1079902 2022-007
    Significant Deficiency
  • 1079903 2022-008
    Significant Deficiency
  • 1079904 2022-009
    Significant Deficiency Repeat
  • 1079905 2022-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $6.71M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $1.71M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.01M
93.498 Provider Relief Fund $547,931
93.558 Temporary Assistance for Needy Families $524,287
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $471,979
93.994 Maternal and Child Health Services Block Grant to the States $240,000
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $209,692
93.914 Hiv Emergency Relief Project Grants $145,668
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $137,736
93.268 Immunization Cooperative Agreements $116,700
93.917 Hiv Care Formula Grants $98,154
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $66,784
93.235 Affordable Care Act (aca) Abstinence Education Program $60,170
93.145 Aids Education and Training Centers $57,189
14.231 Emergency Solutions Grant Program $4,134