Finding Text
Finding 2024-002 - Procurement and Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care, COVID-19 - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care, Grants for New and Expanded Services Under the Health Center Program and COVID-19 - Grants for New and Expanded Services Under the Health Center Program; COVID-19 - Grants for Capital Development in Health Centers Assistance Listing Numbers: 93.224, 93.527 and 93.526 Federal Award Identification Numbers and Years: Health Center Program Cluster: H8FCS40832 - 2021, H80CS00626 - 2022, H8CS00626 - 2023, H8LCS51759 - 2023, H8KCS49691 - 2023, H8KCS49691 - 2024; COVID-19 - Grants for Capital Development in Health Centers: C8ECS44684 - 2021 Criteria In accordance with 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations. 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 our audit, we noted that BCHN did not perform a timely check at the System for Award Management Exclusions (sam.gov) to verify whether an employee or a vendor had been suspended or debarred before being hired. Cause There is no formal policy in place requiring a check to be performed at sam.gov for prospective employees and vendors. Effect or Potential Effect The condition could result in employees or vendors who are suspended or debarred receiving federal funds. Questioned Costs None. Context 1. Health Center Cluster Program: Five exceptions from a statistically valid sample of five. 2. Grants for Capital Development in Health Centers: Two exceptions from a statistically valid sample of two. Identification as Repeat Finding 1. Health Center Cluster Program: Yes (see prior year finding number 2023-003) Recommendation We recommend Human Resources (HR) personnel/management perform a check at sam.gov prior to the hire of an employee or vendor to ensure the employee or vendor was not suspended or debarred and retain evidence of that verification, including the date it was performed. We also recommend a check at sam.gov be done annually thereafter and evidence of that verification be maintained. Views of Responsible Officials BCHN has engaged a company to aid in the review of vendors and employees that are excluded or debarred. This company checks for exclusion or debarment monthly and provides BCHN with a report indicating that the check was done. The company will alert BCHN if any vendors or employees are flagged. This will help BCHN to ensure that this check is done timely.