Finding 1240167 (2026-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2026
Accepted
2026-10-08

AI Summary

  • Core Issue: The Organization failed to check employees for suspension and debarment, violating federal procurement standards.
  • Impacted Requirements: Compliance with §200.213 and §180.300 is essential to avoid contracting with ineligible parties.
  • Recommended Follow-Up: Develop and implement a written procedure for employee reviews regarding suspension and debarment, ensuring staff are trained on compliance.

Finding Text

Finding 2026.001: 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: H80CS00838-2026 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 ten employees for suspension and debarment testing. For all ten 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

Federal Awards Findings: Finding 2026.001 - 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 United Methodist Western Kansas Mexican-American Ministries, Inc. d/b/a Genesis Family Health acknowledges the audit finding regarding the lack of documented suspension and debarment reviews for clinical providers, as required under Uniform Guidance. Gensis Family Health has developed and implemented a formal written procedure requiring verification of providers against applicable federal exclusion databases, including the Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) and other applicable federal suspension and debarment resources, prior to hire and on an ongoing basis. Genesis Family Health already conducts exclusion and debarment screenings for all newly hired employees and contracted providers prior to the commencement of services. Effective immediately, GFH will: 1. Perform and document an annual review of all licensed providers each January to verify that no individual is suspended, debarred, or otherwise excluded from participation in federal healthcare programs. 2. Maintain documentation of all screening results within personnel and credentialing files. 3. Assign responsibility for annual screening and documentation to the Credentialing and Compliance functions, with oversight by executive management. 4. Include annual monitoring of compliance with this policy within the organization's internal compliance review process. Corrective Action Taken Subsequent to identification of this finding, Genesis Family Health completed OIG exclusion inquiries for all applicable clinical providers in September 2026 and retained supporting documentation demonstrating completion of the reviews. No providers were identified as excluded, suspended, or debarred from participation in federal healthcare programs. Responsible Official Amanda Vaughan, Chief Financial Officer and Tracy Lillibridge, Revenue Cycle Director in coordination with the Credentialing and Compliance staff. Anticipated Completion Date Implemented September 2026; ongoing annual reviews will be conducted each January thereafter. Management Explanation Management notes that this finding resulted from a transition in credentialing personnel and responsibilities during the audit period. While provider credentialing activities continued, documentation evidencing the required exclusion and debarment screening process was not consistently maintained. Following identification of the issue, all required OIG exclusion inquiries for affected clinical providers were completed in September 2026, and formal procedures have been established to ensure annual review and documentation each January going forward. If there are any question regarding this plan, please e-mail Amanda Vaughan at amanda.vaughan@Genesisfh.org.

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $2.99M
93.526 GRANTS FOR CAPITAL DEVELOPMENT IN HEALTH CENTERS $354,914
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $172,356
93.917 HIV CARE FORMULA GRANTS $84,640
93.217 FAMILY PLANNING SERVICES $47,124