Finding 1164439 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-12-10

AI Summary

  • Core Issue: The organization lacks a procedure to verify that vendors and employees involved in federal transactions are not suspended or debarred.
  • Impacted Requirements: This oversight violates 2 CFR, Part 200, which mandates checks against the System for Award Management (SAM) for transactions over $25,000.
  • Recommended Follow-Up: Implement an internal control process to regularly verify all relevant vendors and employees against SAM to ensure compliance.

Finding Text

Finding 2025-002 Federal Program: Federal Agency: United States Department of Health and Human Services Pass-Through Agency: New Hampshire Department of Health and Human Services Program Name: Certified Community Behavioral Health Clinic Expansion Grants AL: 93.696 Federal Award Identification Numbers: #1H79SM086461-01 Federal Award Year: 2025 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization does not currently have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. Context: Of the seventeen employees who met the covered threshold amount and were funded by the award, we randomly selected, using a nonstatistical sample, two employees. Neither employee selected for testing were identified on SAM. Questioned Costs: None noted. Cause and Effect: The Organization was not aware of the requirement to verify vendors and employees against SAM on a regular basis. Identification as a Repeat Finding, if Applicable: N/A

Corrective Action Plan

Management will implement a month-end close checklist or process to track when reconciliations are prepared and reviewed to aid in accurate and timely financial reporting. Responsible party: Pamela Wilson, Chief Financial Officer; (603) 889-6147 x 1533 Anticipated completion date: June 30, 2026

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.23M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $172,160
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $70,845
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $60,000