Finding 1170952 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-01-29
Audit: 384316
Auditor: COHNREZNICK

AI Summary

  • Core Issue: The Center failed to check vendors and employees against suspension and debarment lists as required by federal guidelines.
  • Impacted Requirements: Noncompliance with §200.213 and §180.300, which mandate reviews to prevent contracting with ineligible parties.
  • Recommended Follow-up: Create and implement a written procedure for reviewing vendors and employees for suspension and debarment, ensuring all staff are trained on compliance.

Finding Text

Finding 2025.001: Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S. Department of Agriculture Federal Program Names: WIC Special Supplemental Nutrition Program for Women, Infants and Children WIC Special Supplemental Nutrition Program for Women, Infants and Children - Vouchers (noncash assistance) Federal Assistance Listing Number: 10.557 Federal Award Identification Number and Year: 4513-9007 - 2025 Name of Pass-through Entity: Commonwealth of Massachusetts Department of Public Health Criteria In accordance with §200.213 and §180.300, General Procurement Standards, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition There was no evidence that the Center reviewed vendors or employees for suspension and debarment in accordance with the Uniform Guidance requirements. Cause The Center did not have adequate controls to illustrate review of vendors or employees for any suspensions or debarment. Effect or Possible Effect The Center may procure goods and services from vendors or employee individuals that have been suspended or debarred from doing business with the federal government. Questioned Costs None Context We selected a sample of seven vendors for suspension and debarment testing. For all seven vendors tested, management did not provide adequate supporting documentation for the review and approval of each vendor as to whether they have been suspended or debarred. We selected a sample of five employees for suspension and debarment testing. For all five employees tested, management did not provide adequate supporting documentation for the review and approval of each employee as to whether they have been suspended or debarred. Identification as a Repeat Finding No Recommendation The Center should develop a written procedure to review all vendors and employees in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure vendors and employees are being reviewed for suspension and debarment and there is evidence of a formal review being performed.

Corrective Action Plan

Finding 2025.001 - Procurement, Suspension and Debarment Recommendation The Center should develop a written procedure to review all vendors and individuals in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Repeat Finding No Action Taken To establish, implement, and maintain a standardized screening process that ensures no federal funds are paid to excluded or debarred individuals or vendors, with documented evidence and ongoing monitoring, HealthFirst has developed written policies and procedures, outlining assigned responsibilities, screening frequencies, and documentation & retention. Staff training to correct inaccurate searches have been provided. If there are any question regarding this plan, please e-mail Lisa Jones at ljones@healthfirstfr.org. Sincerely, Lisa Jones Chief Executive Offi

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1170951 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $3.23M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $2.32M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $106,913
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $61,773
93.217 FAMILY PLANNING SERVICES $48,953
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $9,037
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $8,000