Finding 1213504 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-05-01
Audit: 400452
Organization: Seattle Indian Health Board (WA)

AI Summary

  • Core Issue: The Health Board failed to properly check if vendors were suspended or debarred before contracting, risking compliance with federal regulations.
  • Impacted Requirements: The Uniform Guidance mandates checks against the Federal Excluded Parties List for contracts over $25,000, which were not adequately documented.
  • Recommended Follow-Up: Provide updated training for program departments on procurement policies to ensure compliance and proper documentation moving forward.

Finding Text

Finding 2025-002 – Suspension and Debarment (Significant Deficiency in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions more than $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies identified in the suspension and debarment process, include the following: • The program had 18 covered transactions over $25,000. From this full population, we randomly selected a sample of four covered transactions subject to suspension and debarment requirements. For one of the items tested the Health Board could not provide the required evidence that they performed a suspension and debarment search. For all of the items tested the Health Board could not provide the required evidence that there was a bid process or sole source justification used to select the vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is a repeat finding. See prior year finding 2024-002. Recommendation – The Health Board has adequate policies in place, so we recommend that departments overseeing programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors’ findings and will implement the corrective action plan to address the issue identified.

Corrective Action Plan

Finding 2025-002 – Suspension & Debarment (Significant Deficiency in Internal Control Over Compliance) Planned Corrective Action: Following the prior year’s audit, Finance completed a full review of all vendors exceeding the threshold in 2024 and obtained the required documentation. The vendor identified in 2025 was not included in that review because it did not exceed the threshold in 2024. The actions above are designed to ensure vendors are captured based on current-year activity. Seattle Indian Health Board will implement the following specific actions to ensure compliance with Uniform Guidance requirements: - Require a documented SAM.gov suspension and debarment check for all vendors prior to contract execution and once cumulative spending limits exceeds $25,000, regardless of prior year activity. - Require completion and retention of either a competitive bid summary or a written sole source justification for all covered transactions. - Perform a quarterly review of vendors with spend over $25,000 to confirm documentation is complete. Name of Responsible Party: Brian Jonas, Controller Anticipated Completion Date: September 30, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1213497 2025-001
    Material Weakness Repeat
  • 1213498 2025-002
    Material Weakness Repeat
  • 1213499 2025-001
    Material Weakness Repeat
  • 1213500 2025-002
    Material Weakness Repeat
  • 1213501 2025-001
    Material Weakness Repeat
  • 1213502 2025-002
    Material Weakness Repeat
  • 1213503 2025-001
    Material Weakness Repeat
  • 1213505 2025-003
    Material Weakness Repeat
  • 1213506 2025-003
    Material Weakness Repeat
  • 1213507 2025-003
    Material Weakness Repeat
  • 1213508 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.231 EPIDEMIOLOGY PROGRAM $4.77M
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $1.44M
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $1.39M
93.479 GOOD HEALTH AND WELLNESS IN INDIAN COUNTRY $1.25M
93.762 A COMPREHENSIVE APPROACH TO GOOD HEALTH AND WELLNESS IN INDIAN COUNTY – FINANCED SOLELY BY PREVENTION AND PUBLIC HEALTH $1.03M
93.193 URBAN INDIAN HEALTH SERVICES $729,183
93.237 SPECIAL DIABETES PROGRAM FOR INDIANS DIABETES PREVENTION AND TREATMENT PROJECTS $446,870
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $408,298
93.073 BIRTH DEFECTS AND DEVELOPMENTAL DISABILITIES - PREVENTION AND SURVEILLANCE $315,103
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $205,712
93.933 DEMONSTRATION PROJECTS FOR INDIAN HEALTH $177,556
93.441 INDIAN SELF-DETERMINATION $175,214
16.023 SEXUAL ASSAULT SERVICES CULTURALLY SPECIFIC PROGRAM $133,514
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $110,500
93.654 INDIAN HEALTH SERVICE BEHAVIORAL HEALTH PROGRAMS $83,439
93.788 OPIOID STR $72,952