Finding 1165374 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-12-18

AI Summary

  • Core Issue: The organization failed to document checks on SAM.gov to ensure vendors were not suspended or debarred before contracting.
  • Impacted Requirements: Compliance with 2 CFR sections 200.212, 200.318(h), and 180.300 regarding vendor eligibility verification.
  • Recommended Follow-Up: Implement a process to retain SAM.gov verification documentation and consider monthly checks for new and existing vendors.

Finding Text

Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Federal Award Number: NU50CK000556 Award Periods: January 1, 2024 – July 31, 2024 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: The organization did not document that SAM.gov was checked prior to entering into a contract with a vendor. Questioned Costs: None. Context: This condition impacted five of five transactions selected for testing. None of the entities transacted with were determined to be excluded parties per SAM.gov. Cause: Based on the timing of when the grant was received by the Organization (June 2024) and when the period of performance expired (July 2024), the Organization had extremely limited time to accomplish the program objectives. Thus, the organization did not maintain documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Effect: The Organization could potentially entered into a transaction with an entity that has been suspended or debarred. 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. To the extent practicable, the organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Suspension and Debarment Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The organization did not document that Sam.gov was checked prior to entering into a contract with a vendor. 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. To the extent practicable, the organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management recognizes that even though none of the vendors utilized were suspended, debarred or otherwise excluded, the potential for violations increase if the verification is not done prior to engaging in transactions. For grant expenses with federal funding, LCHC management has implemented mandatory SAM.gov verification for all vendors prior to contract execution, with documentation retained in procurement files. LCHC has held meetings where applicable staff have been informed of compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Nelson Planned completion date for corrective action plan: 7/1/2025 If there are any questions regarding this plan, please call Jeffrey Nelson at 872-588-3033

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1165373 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.788 OPIOID STR $649,999
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $572,510
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $316,037
93.926 HEALTHY START INITIATIVE $207,908
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $192,699
93.667 SOCIAL SERVICES BLOCK GRANT $89,708
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $79,836
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $79,343
93.332 COOPERATIVE AGREEMENT TO SUPPORT NAVIGATORS IN FEDERALLY-FACILITATED EXCHANGES $59,511
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $34,834