Finding Text
COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing 21.027 U.S. Department of Treasury Missouri Coalition of Community Health Centers d/b/a Missouri Behavioral Health Council Criteria or Specific Requirement: Procurement, Suspension and Debarment – 45 CFR 75.329, 2 CFR 180 Condition: The Organization does not have adequate policies governing suspension and debarment requirements for the purchase of goods or services charged to federal awards. Specifically, the Organization did not verify that vendors were not suspended, debarred, or otherwise excluded. Cause: The Organization does not include a review of the federal suspended and debarment party list as part of the Organization's procurement policy. Effect or potential effect: Purchases were made that did not adhere to the federal government's suspension and debarment compliance requirements. Questioned Costs: None Context: 100% of eligible contracts were tested totaling $240,000. The Organization did not ensure the vendor was not suspended, debarred, or otherwise excluded before entering into contracts. The vendors were not on the suspended and debarred listing. Identification as a Repeat Finding: Repeat Finding of 2023-004 Recommendation: The Organization should develop a suspension and debarment policy and ensure proper staff education on the policy once established. In addition, the Organization should review the policy on an annual basis to ensure it is consistent with the Uniform Guidance.