FAC Explorer

Finding 1123576 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351508
Organization: Medical University of South Carolina (SC)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The University failed to verify vendor suspension and debarment for 11 out of 40 R&D and 9 out of 13 Congressional Directive transactions before procurement.
  • Impacted Requirements: Non-compliance with 2 CFR section 180.300 and 2 CFR 200.303 regarding vendor checks and internal controls.
  • Recommended Follow-Up: Enhance controls to ensure timely verification of vendor status before procurement and document the results for each transaction.

Finding Text

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity 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 the terms and conditions of the Federal award. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 547122 2024-002
    Significant Deficiency
  • 547123 2024-002
    Significant Deficiency
  • 547124 2024-002
    Significant Deficiency
  • 547125 2024-002
    Significant Deficiency
  • 547126 2024-002
    Significant Deficiency
  • 547127 2024-003
    Material Weakness
  • 547128 2024-002
    Significant Deficiency
  • 547129 2024-002
    Significant Deficiency
  • 547130 2024-002
    Significant Deficiency
  • 547131 2024-002
    Significant Deficiency
  • 547132 2024-004
    Significant Deficiency
  • 547133 2024-002
    Significant Deficiency
  • 547134 2024-002
    Significant Deficiency
  • 547135 2024-002
    Significant Deficiency
  • 1123564 2024-002
    Significant Deficiency
  • 1123565 2024-002
    Significant Deficiency
  • 1123566 2024-002
    Significant Deficiency
  • 1123567 2024-002
    Significant Deficiency
  • 1123568 2024-002
    Significant Deficiency
  • 1123569 2024-003
    Material Weakness
  • 1123570 2024-002
    Significant Deficiency
  • 1123571 2024-002
    Significant Deficiency
  • 1123572 2024-002
    Significant Deficiency
  • 1123573 2024-002
    Significant Deficiency
  • 1123574 2024-004
    Significant Deficiency
  • 1123575 2024-002
    Significant Deficiency
  • 1123577 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $106.00M
93.342 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students $6.50M
93.493 Congressional Directives $3.65M
93.364 Nursing Student Loans $3.20M
93.211 Telehealth Programs $3.00M
93.917 Hiv Care Formula Grants $1.88M
93.264 Nurse Faculty Loan Program (nflp) $1.76M
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $1.39M
84.038 Federal Perkins Loan Program_federal Capital Contributions $1.07M
93.399 Cancer Control $1.02M
93.859 Biomedical Research and Research Training $906,659
16.321 Antiterrorism Emergency Reserve $812,159
93.925 Scholarships for Health Professions Students From Disadvantaged Backgrounds $674,996
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $627,596
12.910 Research and Technology Development $609,889
93.396 Cancer Biology Research $532,043
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $522,971
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $510,567
93.884 Primary Care Training and Enhancement $454,076
93.939 Hiv Prevention Activities Non-Governmental Organization Based $447,940
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $340,417
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $329,890
93.121 Oral Diseases and Disorders Research $310,859
93.877 Autism Collaboration, Accountability, Research, Education, and Support $302,524
93.394 Cancer Detection and Diagnosis Research $299,386
97.044 Assistance to Firefighters Grant $277,769
93.165 Grants to States for Loan Repayment $255,545
66.509 Science to Achieve Results (star) Research Program $223,044
84.063 Federal Pell Grant Program $205,232
93.059 Training in General, Pediatric, and Public Health Dentistry $203,702
16.582 Crime Victim Assistance/discretionary Grants $200,428
16.575 Crime Victim Assistance $193,982
93.867 Vision Research $175,282
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $169,599
93.173 Research Related to Deafness and Communication Disorders $159,166
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $143,005
10.555 National School Lunch Program $135,901
93.879 Medical Library Assistance $131,227
93.838 Lung Diseases Research $114,530
64.U01 Other Federal Assistance $114,060
93.307 Minority Health and Health Disparities Research $112,831
16.123 Community-Based Violence Prevention Program $110,354
93.398 Cancer Research Manpower $110,060
93.393 Cancer Cause and Prevention Research $86,817
12.420 Military Medical Research and Development $83,874
93.279 Drug Use and Addiction Research Programs $77,229
93.865 Child Health and Human Development Extramural Research $75,270
84.033 Federal Work-Study Program $74,323
93.823 Public Health Response, Forecasting, and Analytic Capacities Related to Disease Outbreaks, Epidemics, and Pandemics $72,707
93.110 Maternal and Child Health Federal Consolidated Programs $62,439
81.136 Long-Term Surveillance and Maintenance $55,329
93.273 Alcohol Research Programs $48,491
93.350 National Center for Advancing Translational Sciences $46,830
93.530 Teaching Health Center Graduate Medical Education Payment $43,937
47.076 Stem Education (formerly Education and Human Resources) $42,833
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $41,838
93.397 Cancer Centers Support Grants $37,919
93.945 Assistance Programs for Chronic Disease Prevention and Control $31,669
93.124 Nurse Anesthetist Traineeship $31,272
93.516 Public Health Training Centers Program $31,179
93.361 Nursing Research $29,901
93.310 Trans-Nih Research Support $29,405
84.324 Research in Special Education $28,452
93.866 Aging Research $26,892
93.395 Cancer Treatment Research $25,916
93.765 Pphf-Cdc Partnership: Strengthening Public Health Laboratories $23,818
93.837 Cardiovascular Diseases Research $23,402
84.007 Federal Supplemental Educational Opportunity Grants $20,761
93.234 Traumatic Brain Injury State Demonstration Grant Program $18,990
93.855 Allergy and Infectious Diseases Research $18,849
47.075 Social, Behavioral, and Economic Sciences $17,482
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $14,844
64.RD1 Other Federal Assistance $14,727
93.226 Research on Healthcare Costs, Quality and Outcomes $10,775
93.213 Research and Training in Complementary and Integrative Health $7,279
93.130 Cooperative Agreements to States/territories for the Coordination and Development of Primary Care Offices $7,184
43.003 Exploration $4,786
45.024 Promotion of the Arts Grants to Organizations and Individuals $3,728
93.113 Environmental Health $2,574
93.191 Graduate Psychology Education $2,060
93.236 Grants to States to Support Oral Health Workforce Activities $1,535
43.008 Office of Stem Engagement (ostem) $1,476
93.155 Rural Health Research Centers $1,260
93.839 Blood Diseases and Resources Research $794
93.788 Opioid Str $306
93.959 Block Grants for Prevention and Treatment of Substance Abuse $190
93.732 Mental and Behavioral Health Education and Training Grants $73
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $54
93.RD1 Test for Suppression Effects of Advanced Energy $-35
93.103 Food and Drug Administration Research $-5,256
93.242 Mental Health Research Grants $-5,662
93.107 Area Health Education Centers $-7,102
93.247 Advanced Nursing Education Workforce Grant Program $-7,616
47.083 Integrative Activities $-8,359
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $-19,326