Finding Text
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Assistance Listing Number: 93.318 Federal Award Identification Number and Year: NU3HCK000011/2021 Award Period: 1/1/2025 – 12/31/2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: In accordance with 2 CFR §200.214 and 2 CFR Part 180, nonfederal entities are prohibited from entering into covered transactions with suspended or debarred parties. The OMB Compliance Supplement requires the entity to establish and maintain internal controls to ensure compliance with suspension and debarment requirements. Condition: During testing, we noted the Society performed suspension and debarment evaluations on vendors (e.g., SAM.gov verification), however did not retain documentation demonstrating that these vendor evaluations were completed prior to contract execution. Questioned costs: None. Context: Documentation reviewed lacked sufficient date and time stamping to evidence when the evaluation was performed. This condition was identified for all items tested; however, we independently verified that the vendors selected were not suspended or debarred. Cause: The Society did not maintain adequate documentation to support that suspension and debarment procedures were performed timely. Effect: Although no instances of noncompliance were identified, the lack of documented evidence supporting the timely performance of suspension and debarment procedures increases the risk that the Society could enter into transactions with ineligible parties. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Society enhance controls to ensure adequate documentation is retained to support the procedures are performed timely with respect to vendor evaluation for suspension or debarment. Views of responsible officials: There is no disagreement with the audit finding. Management has developed a corrective action plan to address the matter identified which is presented in the accompanying Corrective Action Plan.