Finding Text
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Program Information: Assistance Listing Number: 93.516 Public Health Training Centers Program Federal Award Project Title: Community Health Worker Training Program Federal Award Identification Number: T2946692 Award Number: 6 T29HP46692-01-01 Federal Award Date: November 14, 2022 Project Period: September 15, 2022 – September 14, 2025 Questioned Costs: None Compliance Requirement: Procurement and Suspension and Debarment U.S DEPARTMENT OF LABOR Program Information: Assistance Listing Number: 17.285 Registered Apprenticeship Program Federal Award Project Title: Accelerated Pre-Apprenticeship Program for New Immigrants Federal Award Identification Number: 24A60AP000078 Award Number: 24A60AP000078-01-00 Federal Award Date: June 26, 2024 Project Period: July 1, 2024 – June 30, 2028 Questioned Costs: None Compliance Requirement: Procurement and Suspension and Debarment 2024-001 Policy and Procedure for Suspension and Debarment Material Weakness Condition: The non-profit organization (NFP) does not have a documented policy or procedure in place for verifying that vendors, subrecipients, and contractors are not suspended or debarred from receiving federal funds prior to entering into a covered transaction. Criteria: The Code of Federal Regulations (CRF) Section 2 CFR Section 180 requires written procedures that comply with federal standards for suspension and debarment. Cause: Management was not aware of the specific federal requirement to verify the suspension and debarment status of vendors and subrecipients, believing the standard procurement process was sufficient. The organization has no formal documented policy in place for the requirement of 2 CFR Section 180 of the CFR. Effect: AACF is not in compliance with 2 CFR Section 180. Repeat Finding: No. Auditor’s Recommendation: We recommend AACF adopt a formal written policy in the format and with the elements required by 2 CFR Section 180. Views of Responsible Officials and Planned Correct Action: AACF concurs with this finding. AACF leadership, including its Board and Executive Director, will review and update the organization’s fiscal policies and procedures within 90 days to ensure compliance with Uniform Guidance requirements. All contractors will be required to certify that neither their agency nor any of their principals are debarred or suspended from doing business with the federal government. The Executive Director will be responsible for ensuring this documentation is obtained prior to executing any contractual agreements moving forward. In addition, the Director of Operations will conduct debarment checks for all applicable vendors through SAM.gov in 2024 and 2025 and will provide the results to the Executive Director for review within 30 days.