Finding Text
2025-004 Suspension and Debarment Program Information Federal Organizations U.S Department of Health and Human Services U.S Department of Agriculture (passed through California Department of Public Health) Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award Numbers H80CS00540-23, H8GCS48292, H8LCS51370, 22-10237 A05 Criteria Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transactions (procurement contracts, purchase orders, or agreements greater than or equal to $25,000) with persons or vendors. [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Condition The Organization entered into covered transactions without verification that vendors/contractors were not excluded from doing business with the federal government. This finding appears to be a systemic issue. Cause The Organization did not maintain documentation evidencing its compliance with its policy to verify that persons or entities contracted with were not listed on the exclusions list prior to entering into the contracts or purchase agreements. Effect The Organization may have entered into covered transactions with persons who have been suspended or debarred. Questioned Costs None noted. Context We tested four vendors with “covered transactions” under assistance listing numbers 93.224 and 93.527 and six under assistance listing number 10.557. All vendors selected were missing evidence of suspension and debarment checks being performed. However, we were able to independently verify that the vendors in question were not excluded through SAM.GOV. Recommendation We recommend the Organization perform vendor checks prior to entering into procurements meeting the covered transaction criteria, and retain documentation that the checks were performed and when they were performed. In addition, we recommend that the Organization update these checks on an annual basis. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.