FAC Explorer

Finding 1080788 (2023-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-10-31
Audit: 326910
Organization: Kodiak Area Native Association (AK)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: Procurement documentation lacked evidence of checking contractor status against the SAM Exclusions list, risking federal funds being awarded to ineligible entities.
  • Impacted Requirements: Compliance with 2 CFR Part 180, which mandates verification of contractor eligibility before awarding federal contracts.
  • Recommended Follow-Up: Establish and enforce a policy to retain evidence of SAM Exclusions searches; conduct self-reviews of past contracts funded by federal awards to ensure compliance.

Finding Text

Finding 2023-003 Procurement, Suspension and Debarment – Noncompliance and Significant Deficiency in Internal Control over Compliance Agency Department of Health and Human Services Assistance Listing Numbers (ALN) and Program Name 93.224 & 93.527 - Health Center Program Cluster – Community Health Centers/ Grants for New and Expanded Services under the Health Center Program Criteria or Specific Requirement The regulations in 2 CFR Part 180 restrict contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participant in Federal programs or activities. Procurement policies should be established to ensure documentation is retained to verify a check was done of the Governmentwide System for Award Management Exclusions – (SAM Exclusions) prior to awarding of contracts that will be funded with federal awards. Condition Evidence was not retained in procurement documentation to support confirmation of contractor status in SAM Exclusions as an entity not subject to suspension or debarment. Cause The Association’s policies over procurement were not designed appropriately to retain evidence of SAM Exclusions search suspension and debarment review for all contracts funded with federal awards. Effect or Potential Effect Federal funds could be disbursed to suspended or debarred entities. Questioned costs Not applicable. Context Procurement testing identified a total of 1 out of 1 contracts that did not have support that the SAM Exclusions search was conducted. A contemporaneous search of SAM Exclusions did not identify these vendors as excluded. Identification as a repeat finding Not a repeat finding. Recommendation A policy should be established and enforced to ensure that evidence of the SAM Exclusions search is retained. Staff should conduct self-review of procurement files for contracts awarded in prior years if it is known that the contract will be funded with a federal award to ensure that the SAM Exclusions search is performed prior to the expenditures of those funds and included in the procurement file. Views of responsible officials Management concurs with the finding and will adhere to the corrective action plan. Management plans to perform reviews of procurement contracts in place.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 504337 2023-005
    Significant Deficiency
  • 504338 2023-005
    Significant Deficiency
  • 504339 2023-005
    Significant Deficiency
  • 504340 2023-005
    Significant Deficiency
  • 504341 2023-005
    Significant Deficiency
  • 504342 2023-005
    Significant Deficiency
  • 504343 2023-005
    Significant Deficiency
  • 504344 2023-005
    Significant Deficiency
  • 504345 2023-003
    Significant Deficiency
  • 504346 2023-003
    Significant Deficiency
  • 504347 2023-004
    Significant Deficiency
  • 504348 2023-004
    Significant Deficiency
  • 1080779 2023-005
    Significant Deficiency
  • 1080780 2023-005
    Significant Deficiency
  • 1080781 2023-005
    Significant Deficiency
  • 1080782 2023-005
    Significant Deficiency
  • 1080783 2023-005
    Significant Deficiency
  • 1080784 2023-005
    Significant Deficiency
  • 1080785 2023-005
    Significant Deficiency
  • 1080786 2023-005
    Significant Deficiency
  • 1080787 2023-003
    Significant Deficiency
  • 1080789 2023-004
    Significant Deficiency
  • 1080790 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $2.47M
15.U02 Public Law 102-477 Program $1.56M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $832,724
93.654 Indian Health Service Behavioral Health Programs $569,948
15.021 Consolidated Tribal Government Program $553,393
84.250 American Indian Vocational Rehabilitation Services $525,767
93.210 Tribal Self-Governance Program: Ihs Compacts/funding Agreements $432,957
16.841 Voca Tribal Victim Services Set-Aside Program $399,982
93.237 Special Diabetes Program for Indians_diabetes Prevention and Treatment Projects $283,441
16.589 Rural Domestic Violence, Dating Violence, Sexual Assault, and Stalking Assistance Program $282,671
93.958 Block Grants for Community Mental Health Services $256,473
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $247,446
15.020 Aid to Tribal Governments $238,819
93.558 Temporary Assistance for Needy Families $232,078
15.144 Indian Child Welfare Act_title II Grants $210,751
93.788 Opioid Str $194,715
93.653 Indian Health Service Domestic Violence Prevention Programs $165,382
66.926 Indian Environmental General Assistance Program (gap) $129,607
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $110,292
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $107,451
93.800 Organized Approaches to Increase Colorectal Cancer Screening $100,417
15.156 Cooperative Landscape Conservation $99,299
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $94,304
11.302 Economic Development_support for Planning Organizations $76,667
93.556 Promoting Safe and Stable Families $76,204
66.472 Beach Monitoring and Notification Program Implementation Grants $55,752
16.758 Improving the Investigation and Prosecution of Child Abuse and the Regional and Local Children's Advocacy Centers $55,160
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $51,282
93.054 National Family Caregiver Support, Title Vi, Part C, Grants to Indian Tribes and Native Hawaiians $50,604
45.311 Native American and Native Hawaiian Library Services $41,111
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $27,767
16.710 Public Safety Partnership and Community Policing Grants $27,235
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $25,704
20.205 Highway Planning and Construction $25,583
66.812 Hazardous Waste Management Grant Program for Tribes $23,006
10.575 Farm to School Grant Program $15,950
11.431 Climate and Atmospheric Research $14,259
84.181 Special Education-Grants for Infants and Families $14,171
66.202 Congressionally Mandated Projects $14,012
93.071 Medicare Enrollment Assistance Program $10,191
93.053 Nutrition Services Incentive Program $5,258
15.030 Indian Law Enforcement $4,496
93.645 Stephanie Tubbs Jones Child Welfare Services Program $923
93.047 Special Programs for the Aging_title Vi, Part A, Grants to Indian Tribes_part B, Grants to Native Hawaiians $29