Finding Text
Suspension and Debarment (Material Weakness in Internal Control Over Compliance)
Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180).
Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs:
• Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search.
• Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search.
However, based on our testing, we noted none of the vendors were suspended or debarred.
Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance.
Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts.
Questioned Costs – There were no questioned costs associated with this finding.
Repeat Finding – This is not a repeat finding.
Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements.
Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.