Finding 1176620 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-05

AI Summary

  • Core Issue: The Association lacks proper procedures to verify that subrecipients are not suspended or debarred before contracts are signed.
  • Impacted Requirements: This finding violates 2 CFR Part 200, which mandates compliance with procurement and debarment regulations.
  • Recommended Follow-Up: Implement controls to ensure thorough reviews of subrecipients’ status before entering into any agreements.

Finding Text

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Community Project Funding/Congressionally Directed Spending ‐ Construction Assistance Listing Number: 93.493 Federal Award Identification Number and Year: 6-CE1HS52375-07 - 2023 Award Period: September 30, 2023, through September 29, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance – Suspension and Debarment • Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions that are suspended or debarred. Before entering into a covered transaction, the Association must verify that the subrecipient is not suspended, debarred, or otherwise excluded from participating in the transaction. Condition: Evidence of suspension and debarment procedures was not available for the five subrecipients selected for testing. Questioned costs: None. Context: Of the five subrecipients selected for testing, we noted that none of them had proper suspension and debarment procedures in place. Cause: The Association’s internal controls were not sufficient to ensure that subrecipients/contractors’ suspension and debarment status was documented prior to entering into the contract. Effect: The Association could have entered into an agreement with a subrecipient that was suspended or debarred. Although the Association was able to demonstrate that contracts were not entered into with subrecipients who were suspended or debarred, the absence of documentation performed prior to contract execution presents a risk of noncompliance with applicable procurement regulations. Repeat Finding: N/A.Recommendation: We recommend the Association design controls to ensure an adequate review process is in place to review potential subrecipients, contractors, or vendors to determine they are not suspended or debarred prior to entering into transactions. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend the Association design controls to ensure an adequate review process is in place to review potential subrecipients, contractors, or vendors to determine they are not suspended or debarred prior to entering into transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OARN's vendor approval process has included the following steps:● Review and Verification: Review the Vendor Approval Form to ensure it is complete and includes all necessary documentation. Verify that the vendor is not excluded from receiving federal contracts by checking for debarment on SAM.gov. ● Decision: Approve or deny the Approval Form. ● Communication and Record-Keeping: Return a signed and dated copy to the vendor, indicating approval or denial. Enter information for all approved vendors into the grant management tracking system. OARN recognizes that an essential best practice for federal compliance is conducting semi-annual checks on SAM.gov to confirm a vendor's continued eligibility for federal funds. Effective January 1, 2026, OARN implemented a policy to review all vendors' status on SAM.gov. This initial review is scheduled for completion by February 28, 2026. A subsequent review will take place in July 2026 for any vendors involved in projects that are still ongoing. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: February 28, 2026

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1176619 2025-002
    Material Weakness Repeat
  • 1176621 2025-004
    Material Weakness Repeat
  • 1176622 2025-005
    Material Weakness Repeat
  • 1176623 2025-006
    Material Weakness Repeat
  • 1176624 2025-007
    Material Weakness Repeat
  • 1176625 2025-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.493 Community Project Funding/Congressionally Directed Spending ‐ Construction $2.11M