FAC Explorer

Finding 1239397 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414197
Organization: Iowa Health System and Subsidiaries Dba Unitypoint Health (IA)
Auditor: KPMG LLP

AI Summary

  • Core Issue: The current vendor monitoring process does not ensure timely reviews for exclusions, risking payments to suspended or debarred vendors.
  • Impacted Requirements: This situation violates 2 CFR 200.318, which mandates documented procurement procedures for federal awards.
  • Recommended Follow-up: Strengthen vendor review processes and ensure timely updates to avoid future documentation gaps and compliance issues.

Finding Text

2 CFR 200.318 requires that recipients and subrecipients must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. Management has a control in place to monitor vendors for suspension and debarment (“excluded”). The control is not designed to provide for review of vendors and personnel who are potentially excluded on a timely enough basis. In 2025, the System transitioned exclusion monitoring partners, systems, and supporting processes while also onboarding a new employee who was responsible for this work. Documentation gaps were discovered upon this employee’s departure in June 2026 and new procedures were implemented at that time. Lack of review could result in reimbursement of expenditures paid to a suspended or debarred vendor or person, which is not allowed under ALN 21.027.

Corrective Action Plan

Personnel Responsible for Corrective Action: Ryan Willhite, Executive Director, Internal Audit and ERM Anticipated Completion Date: 10/31/2026 Corrective Action Plan: Exclusion monitoring procedures were updated in June 2026 to memorialize expectations for documenting resolution of matches and submitting provider status change requests timely. Additionally, formal timing thresholds will be established for resolution of any UPH matches to exclusion listings.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1239390 2025-001
    Material Weakness Repeat
  • 1239391 2025-001
    Material Weakness Repeat
  • 1239392 2025-001
    Material Weakness Repeat
  • 1239393 2025-001
    Material Weakness Repeat
  • 1239394 2025-001
    Material Weakness Repeat
  • 1239395 2025-001
    Material Weakness Repeat
  • 1239396 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $6.21M
93.364 NURSING STUDENT LOANS $1.37M
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.27M
84.063 FEDERAL PELL GRANT PROGRAM $1.23M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $944,960
10.766 COMMUNITY FACILITIES GRANT $736,531
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $484,335
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $322,050
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $287,797
93.459 National Bioterrorism Hospital Preparedness Program $244,557
93.912 RURAL HEALTH CARE SERVICES OUTREACH, RURAL HEALTH NETWORK DEVELOPMENT AND SMALL HEALTH CARE PROVIDER QUALITY IMPROVEMENT $243,369
93.264 NURSE FACULTY LOAN PROGRAM (NFLP) $200,463
10.558 CHILD AND ADULT CARE FOOD PROGRAM $186,245
93.778 MEDICAL ASSISTANCE PROGRAM $181,677
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $165,966
93.788 OPIOID STR $149,479
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $146,816
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $145,844
17.285 REGISTERED APPRENTICESHIP $126,412
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $110,180
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $103,261
16.575 CRIME VICTIM ASSISTANCE $102,261
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $95,067
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $90,622
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $89,330
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $83,568
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $70,396
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $67,017
84.033 FEDERAL WORK-STUDY PROGRAM $65,969
97.008 Non-Profit Security Program $64,450
16.758 IMPROVING THE INVESTIGATION AND PROSECUTION OF CHILD ABUSE AND THE REGIONAL AND LOCAL CHILDREN'S ADVOCACY CENTERS $49,792
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $44,521
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $36,336
93.590 Community-Based Child Abuse Prevention Grants $35,177
93.917 SYNDEMIC PREVENTION OUTREACH AND TESTING SERVICES (SPOTS) $34,557
10.855 DISTANCE LEARNING AND TELEMEDICINE LOANS AND GRANTS $33,824
93.235 TITLE V STATE SEXUAL RISK AVOIDANCE EDUCATION (TITLE V STATE SRAE) PROGRAM $32,183
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $31,050
14.905 LEAD HAZARD REDUCTION DEMONSTRATION GRANT PROGRAM $20,675
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $20,073
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $19,910
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $19,072
93.940 Syndemic Prevention Outreach and Testing Services (SPOTS) $15,586
93.563 CHILD SUPPORT SERVICES $13,080
93.366 STATE ACTIONS TO IMPROVE ORAL HEALTH OUTCOMES AND PARTNER ACTIONS TO IMPROVE ORAL HEALTH OUTCOMES $10,638
93.917 HIV CARE FORMULA GRANTS $7,844
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $6,263
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $5,869
93.217 FAMILY PLANNING SERVICES $4,000
93.270 Viral Hepatitis Prevention and Control $3,826
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $3,195
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $3,075
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $2,536
14.913 HEALTHY HOMES PRODUCTION PROGRAM $1,171
93.669 CHILD ABUSE AND NEGLECT STATE GRANTS $289
97.036 COVID-19 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $-12,145