Finding Text
2025-005 Suspension and Debarment Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684 Criteria [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transaction (procurement contracts, purchase orders or agreements greater than or equal to $25,000) with persons or vendors. Condition The Organization entered into covered transactions without verification that vendors/contractors were not excluded from doing business with the federal government. This finding appears to be a systemic problem Cause The Organization did not follow its policy to verify that persons or entities contracted with were not listed on the exclusions list prior to entering into the contracts or purchase agreements. Effect The Organization may have entered into covered transactions with persons who have been suspended or debarred. Questioned Costs None noted. Context Out of four covered transactions selected, only one included evidence that an exclusion check was performed prior to signing the contract. Exclusions checks were performed after documentation was requested by the auditor and no excluded vendors were identified. Recommendation We recommend the Organization implement controls requiring that exclusion checks be performed prior to signing any contracts or purchase orders or agreements that are covered transactions. This exclusion check should be maintained as part of the supporting documentation for the expenditure. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.