Finding 1227858 (2023-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-08-26
Audit: 409789
Organization: Island Health, Inc. (MA)
Auditor: COHNREZNICK LLP

AI Summary

  • Core Issue: The Center failed to verify if vendors and employees were suspended or debarred, violating federal guidelines.
  • Impacted Requirements: Non-compliance with §200.213 and §180.300 regarding eligibility for federal assistance programs.
  • Recommended Follow-Up: Establish a written procedure for reviewing vendors and employees for suspension and debarment, ensuring staff are trained on compliance.

Finding Text

Finding 2023.005: Procurement, Suspension and Debarment - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) COVID -19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Grants for New and Expanded Services under the Health Center Program COVID-19 Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number and Year: H8026638 - 2022 and 2023, H8F40829 - 2021 and H8G48040-2023 Criteria In accordance with §200.213 and §180.300, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition There was no evidence that the Center reviewed vendors and employees for suspension and debarment in accordance with the Uniform Guidance requirements. Cause The Center did not have adequate controls to illustrate review of vendors and employees for any suspensions or debarment. Effect or Potential Effect The Center may procure goods and services from vendors and employees that have been suspended or debarred from doing business with the federal government. Questioned Costs None. Context We selected a sample of 7 vendors for suspension and debarment for testing. For 2 of the 7 vendors tested, management did not provide adequate supporting documentation for the review and approval of each vendor as to whether they have been suspended or debarred. We selected a sample of 7 employees for suspension and debarment for testing. For 1 of the 7 employees tested, management did not provide adequate supporting documentation for the review and approval of the employee as to whether they have been suspended or debarred. Identification of Repeat Finding Yes, see finding 2022.005. Recommendation The Center should develop a written procedure to review all vendors and individuals in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure vendors and employees are being reviewed for suspension and debarment and there is evidence of a formal review being performed.

Corrective Action Plan

Item 2023.005 – Procurement, suspension and debarment Recommendation The Center should develop a written procedure to review all vendors and individuals in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: • As part of our vendor and individual review process, we will ensure that we will document the date and result of the SAM database search, maintaining the results in a centralized file, ensuring records are easily accessible for audit and compliance purposes. • Require approval during the procurement process for new vendors before entering into contracts or agreements • Conduct regular internal reviews to ensure compliance

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1227841 2023-003
    Material Weakness Repeat
  • 1227842 2023-004
    Material Weakness Repeat
  • 1227843 2023-005
    Material Weakness Repeat
  • 1227844 2023-006
    Material Weakness Repeat
  • 1227845 2023-007
    Material Weakness Repeat
  • 1227846 2023-003
    Material Weakness Repeat
  • 1227847 2023-004
    Material Weakness Repeat
  • 1227848 2023-005
    Material Weakness Repeat
  • 1227849 2023-006
    Material Weakness Repeat
  • 1227850 2023-007
    Material Weakness Repeat
  • 1227851 2023-003
    Material Weakness Repeat
  • 1227852 2023-004
    Material Weakness Repeat
  • 1227853 2023-005
    Material Weakness Repeat
  • 1227854 2023-006
    Material Weakness Repeat
  • 1227855 2023-007
    Material Weakness Repeat
  • 1227856 2023-003
    Material Weakness Repeat
  • 1227857 2023-004
    Material Weakness Repeat
  • 1227859 2023-006
    Material Weakness Repeat
  • 1227860 2023-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care $365,690
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $209,873
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $103,743
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $54,138
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $41,299