Finding Text
2021-006 Suspension and DebarmentProgram Information Federal Agency U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers 21H8FCS41567C6, H8C35204, H8D36710, H7CHA37307 Criteria [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness 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 transaction (procurement contracts, purchase orders, or agreements greater than or equal to $25,000) with persons or vendors. Condition The Organization did not retain appropriate evidence of verification that vendors and contractors were not excluded from doing business with the federal government. Context This finding appears to be a systemic problem. Out of four covered vendors selected, none had evidence that an exclusion check was performed prior to related expenditures. Cause The Organization did not retain for its records proof that the verification check of vendors and contractors was made, and did not have policies and procedures in place to ensure this was done. Effect The Organization may have entered into covered transactions with persons or vendors who have been suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Organization implement controls requiring that exclusion checks be performed prior to signing any contracts or purchase orders or agreements that are covered transactions. This exclusion checks should be maintained as part of the supporting documentation for the expenditure. View of responsible officials and planned corrective action The Organization acknowledges the material weakness related to the lack of documented verification of vendor suspension and debarment status. While the organization is confident vendors were appropriate screened through SAM.gov - we acknowledge proper supporting documentation was not maintained. Corrective Actions • Policy and Procedure Implementation: The Organization has implemented formal procurement procedures requiring suspension and debarment (SAM) checks prior to entering into any covered transactions exceeding $25,000. • Documentation Requirements: Evidence of exclusion checks is now required to be retained and maintained with the supporting procurement and expenditure documentation. • Process Integration and Oversight: Exclusion verification has been incorporated into the procurement and approval workflow to ensure compliance is performed consistently before contract execution or payment. In alignment with broader control enhancements noted previously, these actions establish a consistent and documented process to ensure compliance with federal requirements and prevent engagement with excluded or disqualified parties going forward.