Finding 1101565 (2023-008)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-02-28

AI Summary

  • Core Issue: The Organization failed to properly screen vendors for suspension or debarment, risking noncompliance with federal regulations.
  • Impacted Requirements: Non-compliance with 2 CFR §200.303 and §200.214 regarding internal controls and vendor eligibility.
  • Recommended Follow-Up: Implement internal controls for vendor screening and formalize an annual review policy for existing contracts.

Finding Text

Information on the federal program – All federal programs Criteria or specific requirement – As stated in 2 CFR §200.303, the non-federal entity (i.e., the Center) must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations and terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-federal entity is 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. Condition – During the 2022 audit, the predecessor auditor noted several cases in which the Organization did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. The matter has not been resolved in 2023. Cause – Management did not have effective internal controls in place to ensure that suspension and debarment was being performed prior to entering into contracts with vendors or contractors/consultants. Effect or potential effect – The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. Questioned costs – None Context – The Organization failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a repeat finding, if applicable – Is a repeat finding (2022-010) Recommendation – We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well. Views of responsible officials and planned corrective actions – See separate auditee document for planned corrective action.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 525109 2023-004
    Significant Deficiency Repeat
  • 525110 2023-005
    Significant Deficiency
  • 525111 2023-005
    Significant Deficiency
  • 525112 2023-005
    Significant Deficiency
  • 525113 2023-005
    Significant Deficiency
  • 525114 2023-005
    Significant Deficiency
  • 525115 2023-006
    Significant Deficiency Repeat
  • 525116 2023-006
    Significant Deficiency Repeat
  • 525117 2023-006
    Significant Deficiency Repeat
  • 525118 2023-007
    Significant Deficiency
  • 525119 2023-007
    Significant Deficiency
  • 525120 2023-007
    Significant Deficiency
  • 525121 2023-007
    Significant Deficiency
  • 525122 2023-007
    Significant Deficiency
  • 525123 2023-008
    Significant Deficiency Repeat
  • 525124 2023-008
    Significant Deficiency Repeat
  • 525125 2023-008
    Significant Deficiency Repeat
  • 525126 2023-008
    Significant Deficiency Repeat
  • 525127 2023-008
    Significant Deficiency Repeat
  • 525128 2023-008
    Significant Deficiency Repeat
  • 525129 2023-008
    Significant Deficiency Repeat
  • 525130 2023-008
    Significant Deficiency Repeat
  • 525131 2023-009
    Significant Deficiency Repeat
  • 525132 2023-009
    Significant Deficiency Repeat
  • 525133 2023-009
    Significant Deficiency Repeat
  • 525134 2023-009
    Significant Deficiency Repeat
  • 525135 2023-009
    Significant Deficiency Repeat
  • 525136 2023-009
    Significant Deficiency Repeat
  • 525137 2023-009
    Significant Deficiency Repeat
  • 525138 2023-009
    Significant Deficiency Repeat
  • 1101551 2023-004
    Significant Deficiency Repeat
  • 1101552 2023-005
    Significant Deficiency
  • 1101553 2023-005
    Significant Deficiency
  • 1101554 2023-005
    Significant Deficiency
  • 1101555 2023-005
    Significant Deficiency
  • 1101556 2023-005
    Significant Deficiency
  • 1101557 2023-006
    Significant Deficiency Repeat
  • 1101558 2023-006
    Significant Deficiency Repeat
  • 1101559 2023-006
    Significant Deficiency Repeat
  • 1101560 2023-007
    Significant Deficiency
  • 1101561 2023-007
    Significant Deficiency
  • 1101562 2023-007
    Significant Deficiency
  • 1101563 2023-007
    Significant Deficiency
  • 1101564 2023-007
    Significant Deficiency
  • 1101566 2023-008
    Significant Deficiency Repeat
  • 1101567 2023-008
    Significant Deficiency Repeat
  • 1101568 2023-008
    Significant Deficiency Repeat
  • 1101569 2023-008
    Significant Deficiency Repeat
  • 1101570 2023-008
    Significant Deficiency Repeat
  • 1101571 2023-008
    Significant Deficiency Repeat
  • 1101572 2023-008
    Significant Deficiency Repeat
  • 1101573 2023-009
    Significant Deficiency Repeat
  • 1101574 2023-009
    Significant Deficiency Repeat
  • 1101575 2023-009
    Significant Deficiency Repeat
  • 1101576 2023-009
    Significant Deficiency Repeat
  • 1101577 2023-009
    Significant Deficiency Repeat
  • 1101578 2023-009
    Significant Deficiency Repeat
  • 1101579 2023-009
    Significant Deficiency Repeat
  • 1101580 2023-009
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $3.81M
93.676 Unaccompanied Children Program $2.87M
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $1.56M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $1.12M
93.926 Healthy Start Initiative $448,917
93.778 Medical Assistance Program $417,201
93.788 Opioid Str $382,004
93.268 Immunization Cooperative Agreements $372,292
93.526 Grants for Capital Development in Health Centers $362,489
93.310 Trans-Nih Research Support $221,357
93.994 Maternal and Child Health Services Block Grant to the States $114,183
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $86,396
93.217 Family Planning Services $86,353
93.185 Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects $66,886
93.527 Grants for New and Expanded Services Under the Health Center Program $64,286
93.110 Maternal and Child Health Federal Consolidated Programs $49,996
93.297 Teenage Pregnancy Prevention Program $33,250
93.426 The National Cardiovascular Health Program $28,715
16.588 Violence Against Women Formula Grants $17,131
93.917 Hiv Care Formula Grants $9,192
93.504 Family to Family Health Information Centers $7,127