Finding 1143870 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-06-26

AI Summary

  • Core Issue: The Center failed to check SAM.gov for employee debarment status before hiring, violating federal procurement regulations.
  • Impacted Requirements: Noncompliance with §200.213 and §180.300 regarding hiring individuals who are suspended or debarred from federal programs.
  • Recommended Follow-up: Implement written policies for suspension and debarment checks and train staff to ensure compliance and effective internal controls.

Finding Text

Section III - Federal Award Findings and Questioned Costs Finding 2024-001 - Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing Number: 10.557 Federal Award Identification Number and Year: 244NY704W1003; 2023-2024 and 2024-2025 Name of Pass-through Entity: New York State Department of Health Criteria In accordance with §200.213 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition During our testing, we noted that the Center did not perform a timely check at the System for Award Management Exclusions (SAM.gov) to verify whether an employee had been suspended or debarred before being hired. Cause The Center did not have adequate policies, procedures, and controls in place to ensure compliance with the suspension and debarment requirements. Effect or Potential Effect Failure to timely verify that an employee is not suspended or debarred could result in hiring an employee to work on federal grant programs that is barred from performing work for the U.S. government. Questioned Costs None. Context For four suspension and debarment samples out of a total of four tested, management did not provide evidence that a check at sam.gov was performed before hiring. Recommendation We recommend that the Center establish written suspension and debarment policies and procedures to ensure that the Center is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials Our current protocol requires conducting SAM.gov exclusion checks on or before the hire date. However, due to recent administrative transition, some records from 2025 and prior were found to be unavailable. To address this gap, we have re-verified SAM.gov checks for all new hires in 2025 and will continue performing monthly exclusion checks moving forward. All SAM.gov results will be stored electronically to ensure ongoing compliance and proper documentation.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 567428 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $7.02M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $2.19M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.53M
93.268 Immunization Cooperative Agreements $1.05M
93.914 Hiv Emergency Relief Project Grants $579,522
93.493 Congressional Directives $478,780
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $467,114
93.778 Medical Assistance Program $365,977
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $309,629
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $74,913
93.767 Children's Health Insurance Program $25,109