Finding 1239750 (2023-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-10-01

AI Summary

  • Core Issue: The Center failed to check employees and vendors against suspension and debarment lists as required by federal guidelines.
  • Impacted Requirements: Noncompliance with §200.213 and §180.300, which mandate that entities cannot engage with suspended or debarred parties.
  • Recommended Follow-Up: Establish a written procedure for reviewing employees and vendors for compliance, and ensure proper documentation is maintained.

Finding Text

Finding 2023.003: 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 COVID 19 - Health Center Program Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Number: 93.224 and 93.527 Federal Award Identification Number and Year: H80CS00069 - 2022 and 2023, H8FCS40934 - 2021 and 2022, H8LCS51373 - 2023 and H8GCS48391 - 2023 Criteria In accordance with §200.213 and §180.300, General Procurement Standards, nonfederal entities cannot enter into awards, sub-awards, 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 Center reviewed employees or vendors for suspension and debarment in accordance with Uniform Guidance requirements. Cause The Center did not have adequate controls to illustrate review of employees or vendors for any suspensions or debarment. Effect or Potential Effect The Center may procure goods and services from employees or vendors that have been suspended or debarred from doing business with the federal government. Questioned Costs None Context We selected a sample of six vendors and 40 employees for suspension and debarment testing. For all six vendors and four employees tested, management did not provide adequate documentation to support illustration that management tested to ensure that the vendors or employees were not suspended or debarred. Furthermore, there were 10 instances where credentialing documentation was not able to be provided. Identification of Repeat Finding This finding is not a repeat finding. Recommendation The Center should develop a written procedure to review all employees and vendors 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. Furthermore, management should ensure appropriate credentialing documentation is maintained. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure employees and vendors are being reviewed for suspension and debarment and there is evidence of a formal review being performed. In addition, management will ensure appropriate credentialing documentation is maintained.

Corrective Action Plan

Item 2023.003 - Procurement, Suspension and Debarment Recommendation The Center should develop a written procedure to review all employees and vendors 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 Tri-State Community Health Center (TSCHC) concurs with the finding and is implementing written procedures to strengthen the compliance with federal suspension and debarment requirements. TSCHC will establish a more formal process for verifying the suspension and debarment status of applicable employees and vendors in accordance with federal requirements. The procedure will identify the responsible staff, the required verification process, the timing of the review of the automated process, and the documentation that must be maintained as evidence of compliance. Verification documentation will be retained in the appropriate personnel or vendor records, as applicable. TSCHC will also establish procedures for periodic review and monitoring to ensure required continuous automated verifications are completed and appropriately documented. The written procedure will be communicated to appropriate Finance, Human Resources, and other applicable staff. Staff responsible for performing or reviewing suspension and debarment verifications will receive instruction regarding the procedure and documentation requirements. Management will perdiocially review compliance with the procedure and address any identified deficiencies in a timely manner.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1239748 2023-004
    Material Weakness Repeat
  • 1239749 2023-004
    Material Weakness Repeat
  • 1239751 2023-005
    Material Weakness Repeat
  • 1239752 2023-005
    Material Weakness Repeat
  • 1239753 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $3.69M
93.224 HEALTH CENTER PROGRAM $855,218
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $66,074
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $18,893