Finding 1236304 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-24
Audit: 411922
Auditor: KPMG

AI Summary

  • Core Issue: Lack of formal documentation for vendor suspension and debarment checks, which is required for compliance with federal regulations.
  • Impacted Requirements: Non-Federal entities must maintain effective internal controls to ensure compliance with federal statutes and terms of the award.
  • Recommended Follow-Up: Strengthen documentation controls for vendor suspension and debarment validation to meet federal requirements.

Finding Text

U.S. Department of Treasury U.S. Department of Justice Assistance Listing Number: 21.027 16.753 Programs: COVID-19 Coronavirus State and Local Fiscal Recovery Funds/City of Atlanta Diversion Center OJP - Congressionally Recommended Awards/City of Atlanta Diversion Center Award Years: October 1, 2022 – December 31, 2027 (j) Criteria or Requirement Per 2 CFR 200.303, a non-Federal entity must 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. Additionally, there are specific requirements for suspension and debarment for each federal program and are found in the federal statutes, regulations, and the terms and conditions of the federal award pertaining to the program. (k) Condition Found, Including Perspective Formal documentation was not maintained to evidence management’s follow up regarding potential suspension and debarment matches and vendor/supplier registration exemption request forms. (l) Possible Cause While the System performs a suspension and debarment review prior to vendor contracts being entered into and payments being made, controls were not implemented effectively to ensure that documentation was maintained to evidence management’s procedures over ensuring the vendor was not suspended or debarred. (m) Questioned Cost No questioned costs as amounts were noted. (n) Effect Federal funds were expended with vendors whom management did not maintain formal documentation to substantiate that the vendors were not subject to suspension or debarment in accordance with Federal requirements. (o) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (p) Repeat Finding in the Prior Year This finding is not a repeat finding. (q) Recommendation We recommend that the System strengthen controls over maintaining documentation regarding the suspension and debarment validation performed over vendors. (r) View of Responsible Officials Management concurs with the finding. Appropriate controls are in place relative to suspension and debarment policies and procedures. Opportunities exist to further enhance controls related to documenting and maintaining formal documentation related to potential matches and exemption request forms

Corrective Action Plan

Condition: Formal documentation was not maintained to evidence management’s follow up regarding potential suspension and debarment matches and vendor/supplier registration exemption request forms. Corrective Action: Management acknowledges the finding and has reviewed the circumstances that resulted in documentation not being maintained for certain identified vendors. While a vendor screening process currently exists to identify potential matches against federal and state exclusion databases, the process will be enhanced to strengthen documentation, accountability, and consistency, including retrieval of comprehensive vendor listing from the appropriate Grady database for sanction screening and revision of the vendor screening exemption process. Implementation Date: Ongoing Expected Result: These corrective actions are designed to provide reasonable assurance that all vendors doing business with Grady will have documented verification of compliance with specific requirements for suspension and debarment for each federal program. The documentation will provide 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. Responsible Official: D’Andrea Morning, Chief Compliance Officer

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1236301 2025-001
    Material Weakness Repeat
  • 1236302 2025-002
    Material Weakness Repeat
  • 1236303 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $11.27M
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $9.67M
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $1.53M
93.686 ENDING THE HIV EPIDEMIC: A PLAN FOR AMERICA €” RYAN WHITE HIV/AIDS PROGRAM PARTS A AND B $977,114
93.253 POISON CENTER SUPPORT AND ENHANCEMENT GRANT $865,783
93.153 COORDINATED SERVICES AND ACCESS TO RESEARCH FOR WOMEN, INFANTS, CHILDREN, AND YOUTH $727,052
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $604,604
93.778 GRANTS TO STATES FOR MEDICAID $582,582
16.045 COMMUNITY-BASED VIOLENCE INTERVENTION AND PREVENTION INITIATIVE $526,943
16.575 CRIME VICTIM ASSISTANCE $446,134
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $411,053
93.788 OPIOID STR $316,817
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $286,333
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $223,934
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $219,434
93.924 RYAN WHITE HIV/AIDS PROGRAM DENTAL REIMBURSEMENT AND COMMUNITY BASED DENTAL PARTNERSHIP GRANTS $217,455
93.051 ALZHEIMER'S DISEASE DEMONSTRATION GRANTS TO STATES $183,480
93.226 RESEARCH ON HEALTHCARE COSTS, QUALITY AND OUTCOMES $182,053
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $173,350
93.078 STRENGTHENING EMERGENCY CARE DELIVERY IN THE UNITED STATES HEALTHCARE SYSTEM THROUGH HEALTH INFORMATION AND PROMOTION $165,453
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $155,511
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $155,452
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $151,260
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $141,839
84.063 FEDERAL PELL GRANT PROGRAM $116,965
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $103,485
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $77,576
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $77,554
93.121 ORAL DISEASES AND DISORDERS RESEARCH $61,026
93.217 FAMILY PLANNING SERVICES $54,994
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $40,148
93.397 CANCER CENTERS SUPPORT GRANTS $34,667
93.497 FAMILY VIOLENCE PREVENTION AND SERVICES/ SEXUAL ASSAULT/RAPE CRISIS SERVICES AND SUPPORTS $19,153
93.310 TRANS-NIH RESEARCH SUPPORT $10,724
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $5,256
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $138