Finding 1206096 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-04-08

AI Summary

  • Core Issue: The CMHSP failed to verify vendor status on sam.gov before contract agreements, which is a repeat finding from FY 2024.
  • Impacted Requirements: Compliance with 2 CFR and 48 CFR regulations regarding vendor eligibility is not being met.
  • Recommended Follow-Up: Update policies to ensure vendor verification is done prior to contract signing; management agrees with this recommendation.

Finding Text

2025-001: PROCUREMENT (repeat comment) Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.696 Certified Community Behavioral Health Clinics Expansion (CCBHC) Grants Criteria: Per 2 CFR section 200.214 and section 180.300; 48 CFR section 52.209-6, when entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified. Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Contracts for FY 2025 were the same contracts for FY 2024 for this program. Therefore, this finding is a carryover of the FY 2024 finding. Cause/Effect: Management oversight. Questioned Cost: None Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.

Corrective Action Plan

Sanilac County Community Mental Health Authority Corrective Action Plan September 30, 2025 FINDING NUMBER: 2025-001 Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment, and exclusion is conducted prior to entering a contract Planned Corrective Action: Going forward the Authority will follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2025

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.12M
93.778 GRANTS TO STATES FOR MEDICAID $66,755
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $5,267