Finding 1220602 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-29

AI Summary

  • Core Issue: The Company's policies on suspension and debarment do not meet federal standards outlined in 2 CFR 200.213.
  • Impacted Requirements: Lack of controls may lead to non-compliance with federal assistance program eligibility, risking questioned costs.
  • Recommended Follow-Up: Implement formal written policies to ensure compliance with suspension and debarment requirements.

Finding Text

Finding: Documented Policies and Procedures related to Suspension and Debarment Program: State and Regional Primary Care Associations (PCAS), National Technical Assistance Programs (NTAPS), and Health Centered Controlled Networks (HCCNS) Assistance Listing Number: 93.129 Federal Agency: U.S. Department of Health and Human Services Federal Award ID #: N/A Award Period: 7/1/2024-6/30/2027 Criteria or Specific Requirement: Suspension and debarment standards outlined in 2 CFR 200.213 restrict a non-federal entity from entering into contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition: The Company's policies and procedures over suspension and debarment do not conform to the requirements outlined by the Uniform Guidance. Cause: The Company has limited personnel. As such, the Company did not consider controls surrounding suspension and debarment. Effect or Potential Effect: The Company may have failed to comply with various requirements due to lack of formal controls in place to ensure compliance, resulting in questioned costs. Questioned Costs: None Context: During testing of suspension and debarment, and inquiry with management, it was determined that the Company does not have all required internal controls related to these compliance requirements. Forivs Mazars tested 100% of the vendors paid over $25,000 during the grant period. Entity does not maintain evidence of suspension and debarment checks performed. Identification as a Repeat Finding: Not Applicable Recommendation: We recommend the Company implement formal written policies in compliance with suspension and debarment requirements. Views of Responsible Officials: The Company agrees with the finding. See separate report for planned corrective action.

Corrective Action Plan

Documented Policies and Procedures related to Suspension and Debarment Recommendation: ICHCA should implement formal written policies in compliance with suspension and debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: ICHCA staff were provided a refresher on suspension and debarment documentation requirements, and policies and procedures were updated to emphasis the need to retain documentation of exclusion and debarment inquiries. Personnel have been filing documentation with contracts as of April 2026. Name(s) of the contact person(s) responsible for corrective action: Kyle Rooks, CEO Planned completion date for corrective action plan: April 2026

Categories

Procurement, Suspension & Debarment Eligibility

Programs in Audit

ALN Program Name Expenditures
93.129 STATE AND REGIONAL PRIMARY CARE ASSOCIATIONS (PCAS), NATIONAL TECHNICAL ASSISTANCE PROGRAMS (NTAPS), AND HEALTH CENTERED CONTROLLED NETWORKS (HCCNS) $1.41M
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $679,980