Finding 1211101 (2022-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2026-04-30
Audit: 400343
Organization: El Paso Alliance, Inc. (TX)

AI Summary

  • Core Issue: The Organization failed to verify vendor status against suspension or debarment lists before entering into contracts.
  • Impacted Requirements: Noncompliance with 2 CFR sections 200.212, 200.318(h), and 180.300, which mandate verification of vendor eligibility.
  • Recommended Follow-Up: Ensure documentation of SAM.gov checks for vendor status is retained and develop a Corrective Action Plan to strengthen controls.

Finding Text

2022-003 - Suspension and Debarment Finding Type Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance 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 verify that a vendor utilized was not suspended, debarred, or otherwise excluded prior to entering into a transaction. Questioned costs None Context The condition impacted two transactions selected for testing. During the audit, the vendors were checked via Sam.gov and determined to not be included as suspended or debarred. Cause Oversight Effect The Organization could potentially enter into a transaction with an entity that has been suspended or debarred. Repeat Finding No Recommendation We recommend the Organization retain documentation that SAM.gov was used to verify that vendors are not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. View of Responsible Official and Planned Corrective Action The Organization agrees with the recommendations made in this finding. The Organization will examine the controls in place and prepare a Corrective Action Plan.

Corrective Action Plan

U.S Department of Health and Human Services 2022-003 - Suspension and Debarment - Assistance Listing No. 93.243 Recommendation: We recommend the Organization retain documentation that SAM.gov was used to verify that vendors are not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. Explanation of disagreement with the audit finding: There is no disagreement with the audit finding. Action take in response to finding: Management will update procurement procedures to require documented SAM.gov verification for vendors prior to contract execution and periodically for existing vendors. Evidence of verification (e.g., screenshots or confirmation reports) will be retained in procurement files. Compliance will be reviewed as part of routine procurement oversight. Name(s) of the contact person(s) responsible for corrective action: Ben Bass, CEO Planned completion date for corrective action plan: May 2026

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1211100 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES_PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $515,908
93.788 OPIOID STR $173,432