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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.