Finding 393450 (2022-009)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-04-16

AI Summary

  • Core Issue: The Organization lacks a formal suspension and debarment policy, which is essential for compliance with federal regulations.
  • Impacted Requirements: Failure to verify vendors against the excluded parties list may lead to non-compliance with 2 CFR part 180, risking future funding.
  • Recommended Follow-Up: Strengthen policies to ensure proper documentation of suspension and debarment, and regularly verify vendors using sam.gov to maintain compliance.

Finding Text

2022-009: Suspension and Debarment- Material Weakness – Originated in 2019 Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119-22-00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020-2024 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Condition: Under 2 CFR part 180, the Organization is required to verify suspension or debarment from the excluded parties list system regarding compliance. Though the Organization did not have a policy for suspension and debarment, the Organization complied with the requirements. Effect: Not having a suspension and debarment policy may result in funds to be returned back to grantor and/or impact future funding. Cause: Supporting suspension and debarment documentation for the acquisition of property and services were not properly established in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned Costs: None Recommendation: We recommend the Organization strengthen its policies and procedures to ensure suspension and debarment is adequately documented that goods and services purchased in accordance with Uniform Guidance and other federal guidelines. In addition, the Organization should verify that all vendors under covered transactions are not listed on the excluded parties list system by performing a search on sam.gov and maintaining the results of such search in the vendor’s file.

Corrective Action Plan

U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119-21-00 / 6 H49MC00119-20-01 2022-009: Suspension and Debarment- Material Weakness Recommendation: We recommend the Organization strengthen its policies and procedures to ensure suspension and debarment is adequately documented so that goods and services are purchased in accordance with Uniform Guidance and other federal guidelines. In addition, the Organization should verify that all vendors under covered transactions are not listed on the excluded parties list system by performing a search on sam.gov and maintaining the results of such search in the vendor’s file. Grantee Response and Corrective Action Plan 2022-009: In response to the audit finding under 2 CFR part 180 regarding the necessity to verify suspension or debarment status in compliance with the excluded parties list system, it is acknowledged that while the Center for Black Women’s Wellness did not previously have a formal policy specifically addressing suspension and debarment, our practices have nonetheless complied with the requirements. Recognizing the importance of formalizing these practices into policy, we are committed to developing and implementing a comprehensive policy that explicitly addresses these checks. This initiative will be integrated with our existing compliance frameworks to ensure consistent adherence across all procurement activities. In line with our recent enhancements in internal controls, including the engagement of a Contractual CFO in 2024, this policy will reinforce our ongoing efforts to uphold the highest standards of compliance and accountability in all our operations. Responsible Parties: Jemea Dorsey, CEO Date Corrected: April 30, 2024

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 393446 2022-005
    Material Weakness Repeat
  • 393447 2022-006
    Material Weakness Repeat
  • 393448 2022-007
    Material Weakness Repeat
  • 393449 2022-008
    Material Weakness Repeat
  • 393451 2022-005
    Material Weakness Repeat
  • 393452 2022-006
    Material Weakness Repeat
  • 393453 2022-007
    Material Weakness Repeat
  • 393454 2022-008
    Material Weakness Repeat
  • 393455 2022-009
    Material Weakness Repeat
  • 969888 2022-005
    Material Weakness Repeat
  • 969889 2022-006
    Material Weakness Repeat
  • 969890 2022-007
    Material Weakness Repeat
  • 969891 2022-008
    Material Weakness Repeat
  • 969892 2022-009
    Material Weakness Repeat
  • 969893 2022-005
    Material Weakness Repeat
  • 969894 2022-006
    Material Weakness Repeat
  • 969895 2022-007
    Material Weakness Repeat
  • 969896 2022-008
    Material Weakness Repeat
  • 969897 2022-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.926 Healthy Start Initiative $1.05M
93.185 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $68,580
93.310 Trans-Nih Research Support $23,422
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $20,000
14.218 Community Development Block Grants/entitlement Grants $12,645