Finding 1238150 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-29

AI Summary

  • Core Issue: The Organization failed to check employees for suspension and debarment, risking procurement from ineligible individuals.
  • Impacted Requirements: Noncompliance with §200.213 and §180.300 of the Uniform Guidance on procurement standards.
  • Recommended Follow-Up: Create and implement a written procedure for reviewing employee eligibility regarding suspension and debarment.

Finding Text

Finding 2025-003 - 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 Federal Assistance Listing Numbers: 93.224 Federal Award Identification Number and Year: H80CS28372-2024 and 2025 Criteria In accordance with §200.213 and §180.300, General Procurement Standards, nonfederal 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 Organization reviewed employees for suspension and debarment in accordance with the Uniform Guidance requirements. Cause The Organization did not have adequate controls to illustrate review of employees for any suspensions or debarment. Effect or Possible Effect The Organization may procure goods and services from employee individuals that have been suspended or debarred from doing business with the federal government. Questioned Costs None Context We selected a sample of six employees for suspension and debarment testing. For all six employees tested, management did not provide adequate supporting documentation for the review and approval of each employee as to whether they have been suspended or debarred. Identification as a Repeat Finding No Recommendation The Organization should develop a written procedure to review all employees 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 and Planned Corrective Actions Management concurs with the finding and will implement additional controls to ensure employees are being reviewed for suspension and debarment and there is evidence of a formal review being performed.

Corrective Action Plan

Finding 2025.003 - Procurement, Suspension and Debarment - Material Weakness Recommendation The Organization should develop a written procedure to review all employees 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 No Action Taken The Organization will develop a written procurement policy that includes a required suspension and debarment verification step for all covered transactions, consistent with 2 CFR 200. Prior to entering into a covered contract or procurement, staff will verify that the vendor/contractor is not suspended, debarred, or otherwise excluded, using SAM.gov, and will retain documentation of that verification in the procurement file. This policy will be approved by the Board at the September 2026 Board of Directors Meeting and reviewed with all relevant procurement staff. Verification will be performed for every covered procurement going forward.

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $1.15M
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $27,820