Finding Text
Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Awards: Assistance Listing 93.145 – HIV Related Training and Technical Assistance; Assistance Listing 93.153 – Coordinated Services and Access to Research for Women, Infants, Children, and Youth; Assistance Listing 93.939 – HIV Prevention Activities Non-Governmental Organization Based Pass-Through Entity: Assistance Listing 93.145 – University of Pittsburgh (93.145); N/A; N/A Pass-Through Entity Number: Assistance Listing 93.145 – Subaward AWD00009525; N/A; N/A Award Periods: Assistance Listing 93.145 – July 1, 2024 – June 30, 2025; July 1, 2025 – June 30, 2026; Assistance Listing 93.153 – August 1, 2024 – July 31, 2025; August 1, 2025 – July 31, 2026; Assistance Listing 93.939 – April 1, 2024 – March 31, 2025; July 1, 2024 – June 30, 2025; April 1, 2025 – March 31, 2026; July 1, 2025 – June 30, 2026 Section III – Federal Award Findings and Questioned Costs (continued) Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition Management, through the use of a service provider, validates that vendors are reviewed on a monthly basis to ensure they are not suspended or debarred. There was insufficient evidence to support management’s control activities addressing completeness and accuracy of the vendor list provided to the service provider to check for suspension and debarment. Specifically, in the evaluation of the design of the control in operation during 2025, we noted the following: 1. Lack of evidence retained of management’s review of the system generated master vendor listing used as input data prior to validation for the control. 2. Lack of second-level review over manual manipulation and filtering of data in the preparation of the master vendor listing prior to screening. 3. Incomplete identification of vendors subject to federal suspension and debarment requirements. 4. Lack of evidence retained of management’s considerations around the completeness and accuracy of information used in the exercise of the control by the service provider. Cause The System did not perform a review or retain documentation to support the completeness and accuracy of the master vendor list used for suspension and debarment. Effect or potential effect The vendor list used for suspension and debarment screening may not be complete and accurate, increasing the risk that vendors or contractors subject to federal suspension and debarment are not identified before expending federal funds. Section III – Federal Award Findings and Questioned Costs (continued) Questioned costs None. Identification of a repeat finding Not a repeat finding. Context The System utilizes a third-party service provider to perform suspension and debarment screenings. Under the System's policy, all vendors providing goods or services to federally funded programs are required to be included in the suspension and debarment screening process. Given we were aware of the conditions and cause mentioned above at the time of testing, our testing included 100% of the vendors for each of the major programs. We noted control exceptions for the major programs summarized below: • Assistance Listing 93.145 – HIV–Related Training and Technical Assistance: We identified two vendors, which throughout the audit period were not subject to the System’s search of exclusion lists for suspension and debarment. Transactions under these vendors for the period under audit totalled $1,156, which is not material to the major program. A subsequent search for these vendors for the period under audit did not yield any matches, indicating these control failures did not result in a compliance exceptions. • Assistance Listing 93.153 – Coordinated Services and Access to Research for Women, Infants, Children, and Youth: No exceptions were identified. • Assistance Listing 93.939 – HIV Prevention Activities Non–Governmental Organization Based: We identified one vendor that throughout the audit period was not subject to the System’s search of exclusion lists for suspension and debarment. Transactions under this vendor for the period under audit totalled $1,500, which is not material to the major program. A subsequent search for the vendor for the period under audit did not yield any matches, indicating these control failures did not result in a compliance exception. Given the control deficiency relates to the process used to identify vendors to be included in the screening population, the deficiency impacts the control's ability to operate effectively across the major programs above that were subject to testing. Although the omitted vendors were not identified as suspended or debarred, the exceptions demonstrate that the population used for suspension and debarment screening was not complete. Recommendation Management should enhance its suspension and debarment control to ensure all vendors associated with federally funded programs are included in the screening population. Management should maintain evidence of its review of the completeness and accuracy of the vendor population provided to the third-party service provider and the results of the screening process. View of responsible officials There is no disagreement with the audit finding.