Finding Text
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Cluster Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: H80CS12856 Award Periods: March 1, 2023 – February 29, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: As a result of the lack of a suspension and debarment policy, the organization did not document that Sam.gov was checked prior to entering into a contract with a vendor. Questioned costs: None. Context: Five (5) of five (5) vendors selected for testing did not have evidence prior to contracting of a check for suspension and debarment. However, subsequent review showed evidence the vendors were not suspended and debarred. Cause: Employee turnover. Effect: Possible noncompliance with 2 CFR section 200.320(c)(1) - (3). Repeat finding: No. Recommendation: We recommend that the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. The organization can keep screenshots that Sam.gov was checked or a PDF print out of the web page which includes the date verified. Views of responsible officials: There is no disagreement with the audit finding.