Finding Text
Finding 2022 ? 001: Procurement and Suspension and Debarment for Federal Programs Significant Deficiency, Internal Control Over Compliance Assistance Listing Number: 93.591 ? COVID-19 Family Violence Prevention and Services/State Domestic Violence Coalitions / 16.575 ? Crime Victim Assistance Federal Agency: Department of Health and Human Services / Department of Justice Award Year: 2022 Federal Award Identification: 2101MSSDVC, 2101MSSDC6, 2001MSSDC3 (ALN: 93.671) Pass-Through Entity: Mississippi Department of Health (ALN: 93.671 and 16.575) Criteria: In accordance with 2 CFR 200.303 (a), establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. In addition procedures should conform to those detailed in 2 CFR 180.300 through 180.325: ?Responsibilities of Participants Regarding Transactions Doing Business With Other Persons?. Condition: Although no instance of non-compliance were identified, MCADV does not have internal controls in place to ensure compliance with this requirement. Cause: MCADV?s internal control system was not properly designed to ensure that contracting with suspended or debarred parties is prevented. Further, documentation was not available to demonstrate that a procurement policy was in place to address cost and price analysis and vendor selections, where applicable, based on the method of procurement used. MCADV historically contracts with the same vendors year-over-year and did not review the list of suspended or debarred entities to ensure current vendors were not on the suspension or debarment list. Effect: Although no instances of noncompliance were identified, MCADV?s lack of internal control process related to procurement and suspension and debarment, could result in violation of the federal requirement. Questioned Costs: N/A. Identification As A Repeat Finding: Yes. Recommendations: We recommend developing a procurement policy to guide the selection of vendors, further this policy should require the periodic review of vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Views Of Responsible Officials and Planned Corrective Action: MCADV will make the necessary correction for compliance. As a result of the finding, Wendy Mahoney will be responsible for developing a procurement policy to guide the selection of vendors. MCADV will ensure the policy includes the periodic review of those vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Anticipated completion date: September 30, 2023.