Finding Text
Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527
U.S. Department of Health and Human Services
Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024
Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023
Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024
Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213
Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements.
Questioned Costs – None
Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit.
Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place.
Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance.
Identification as a repeat finding, if applicable – Not a repeat finding
Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance.
Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.