Finding Text
Federal Agency: Department of Health and Human Services
Federal Program Name: COVID 19 - Demonstration Programs to Improve Community Mental Health Services
Federal Award Identification Number and Year: H79SM083348 - 2023
Assistance Listing Number: 93.829
Award Period: February 15, 2021 – February 14, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Other Matter - Compliance
Criteria: 2 CFR 200.214 outlines the guidelines for suspension and debarment. According to this regulation, non-Federal entities (which includes organizations receiving federal assistance) are subject to the non-procurement debarment and suspension regulations. These regulations implement Executive Orders 12549 and 12689. Specifically, they are covered by 2 CFR part 180.
Condition: During our testing, we noted the Organization's internal controls were not sufficient to ensure suspension and debarment verification procedures were performed.
Questioned Costs: None.
Context: We noted that Cornerstone Montgomery did not verify timely whether 1 of 1 of its vendors to a covered transaction was suspended or debarred prior to entering into the transaction. We were able to verify that the vendor was not suspended or debarred through checking the exclusion database on Sam.gov.
Cause: Insufficient internal controls of suspension and debarment.
Effect: Lack of determination of if a vendor was suspended or debarred.
Repeat Finding: N/A
Recommendation: We recommend internal controls over suspension and debarment be implemented. This could include following checklist which includes procedures for verification of whether a vendor is suspended or debarred and having that checklist be required to be reviewed by the program manager prior to entry into a covered transaction.
Views of Responsible Officials of the Auditee: A process of more comprehensive review of program requirements will be put in place.