Finding Text
Federal Agency: Department of the Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds 21.027
Federal Award Identification Number: SLFRP0126
Pass-Through Agency: State of Colorado Department of Human Services Behavioral Health Administration
Pass-Through Number(s): 24 IBEH 186887
Award Period: 7/1/2023 – 12/30/2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Center should have internal controls designed to ensure compliance with these provisions.
Condition: During our testing over suspension and debarment, we noted one instance in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor.
Questioned Costs: None
Context: During our testing over suspension and debarment, we noted one instance in which the Center did not perform the suspension and debarment check prior to entering into a transaction with a vendor.
Cause: The purchase was made outside of the normal accounts payable process which resulted in the vendor not being recorded in the vendor listing in NetSuite which is run through the debarment check system.
Effect: Noncompliance with federal regulations.
Repeat Finding: No
Recommendation: We recommend the Center implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors.
Views of responsible officials: The vendor in question was reviewed and vetted by USI, our insurance broker, before being recommended to the Center. The Center began using them as a vendor after USI’s recommendation and they were set up to be paid via an ACH debit so the vendor was not included in our existing accounts payable vendor debarment check. The Center has updated the debarment verification policy to include all payment types to all vendors. Additionally, a debarment check has now been performed on this vendor and they are not debarred and are eligible to receive federal funds.