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Finding 2025-002 - Procurement and Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services. Federal Program Names: Health Center Program and Grants for New and Expanded Services Under the Health Center Program. Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Numbers and Years: Health Center Program Cluster: H80CS00626‐2023, H8KCS49691-2023, H8KCS49691-2024, H8ICS53459-2024 Criteria In accordance with 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition During our audit, we noted that BCHN did not perform a check at the System for Award Management Exclusions (sam.gov) to verify whether a vendor had been suspended or debarred before being hired. Cause As a result of personnel changes, the check was not timely performed. Effect or Potential Effect The condition could result in vendors who are suspended or debarred receiving federal funds. Questioned Costs None. Context One exception from a statistically valid sample of eight. Identification as a Repeat Finding Yes (see prior year finding number 2024-002) Recommendation We recommend Human Resources (HR) personnel/management perform a check at sam.gov prior to the hire of an vendor to ensure the vendor was not suspended or debarred and retain evidence of that verification, including the date it was performed. Views of Responsible Officials The vendor that was selected during the audit was hired in March of 2025. Since that time, BCHN has implemented a process by which all new employees and new vendors are added to the Exclusion Screening LLC database. We engaged Exclusion screening LLC because they check for exclusion and debarment on the OIG, SAM and state exclusion lists monthly, once entered in the system. This process ensures that all new vendors or employees are screened upon hire and are then automatically screened going forward. Bronx Community Health Network, Inc. and Affiliate Schedule of Findings and Questioned Costs Year Ended December 31, 2025 38