Finding Text
Federal Agency: United States Department of Health and Human Services Federal Programs: Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.696 Federal Award Year: 2024-2025 Criteria or Specific Requirement – Suspension and debarment (2 CFR 180) Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Corporation did not perform procedures to ensure vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Corporation did not have adequate controls and procedures in place relating to suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – The Corporation may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded. Questioned Costs – None Context – We selected a sample of one vendor out of a population of two vendors for testing. For the vendor selected, the Corporation was unable to provide evidence the covered transaction was not with a vendor suspended, debarred, or otherwise excluded. As a result, suspension and debarment activities were not completed in accordance with federal regulations nor was supporting documentation retained to demonstrate compliance. The sampling methodology used is not, and is not intended to be, statistically valid. Identification as a Repeat Finding – No Recommendation – The Corporation should incorporate internal controls over compliance with the suspension and debarment compliance requirement including monitoring vendors against the exclusions list. Views of Responsible Officials and Planned Corrective Actions – Management concurs with the finding. Arisa has subsequently received a signed certification from the subcontractor dated 4/20/2026 indicating that the vendor was not debarred, suspended, or otherwise excluded from participation in federal assistance programs. For future federal awards, Arisa will collect a certification from the subcontractor/vendor indicating compliance with this requirement.