Finding 401300 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-06-20

AI Summary

  • Core Issue: The Organization failed to check for suspended or debarred hotel vendors before contracting, which is a significant compliance requirement.
  • Impacted Requirements: Non-federal entities must verify vendor eligibility under 2 CFR sections 200.212 and 200.318(h) to avoid contracting with ineligible parties.
  • Recommended Follow-Up: Enhance training for procurement staff to ensure all necessary suspension and debarment checks are conducted for every applicable contract.

Finding Text

Federal Agency: United States Department of Health and Human Services Federal Program Name: Family Violence Prevention and Services Assistance Listing Number: 93.592 Award Period: 9/30/2022-9/29/2023 Type of Finding: • Significant Deficiency Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6). Condition: The Organization did not perform a SAMS.gov suspension & debarment check for their contracted hotel vendors. Questioned costs: None. Context: Two out of the five samples were deficient. However, CLA elected to a SAMS.gov check on 2/22/24 and noted that both hotels that were selected (Talking Stick Resort and Isleta Resort & Casino) were not debarred. These vendors were not checked as NIWRC was not aware that checks were required for hotels, even when hotels are subject to a contracted agreement (e.g., being used as a venue). Cause: The Organization did not have a system in place to ensure the suspension & debarment compliance requirement was addressed for each applicable covered transactions. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Repeat Finding: No Recommendation: CLA recommends the Organization increase training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed on all covered transactions. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Health and Human Services National Indigenous Women's Resource Center respectfully submits the following corrective action plan for the year ended September 30, 2023: Audit Period: October 1, 2022 to September 30, 2023 The finding from the Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING-MAJOR FEDERAL PROGRAMS SIGNIFICANT DEFICIENCY 2023-001 Suspension & Debarment Recommendation: We recommend the Organization increase training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed on all covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We have informed all individuals involved in procurement and contract approval of the requirement to perform suspension and debarment checks on hotel venues. Additionally, we will provide additional training to provide a better understanding of the procurement and contracting requirements. Name of the contact person responsible for corrective action: Lora Helman Planned completion date for corrective action plan: September 30, 2024 If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Lora Helman at lhelman@niwrc.org.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 977742 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.496 Family Violence Prevention and Services/culturally Specific Domestic Violence and Sexual Violence Services $688,499
16.841 Voca Tribal Victim Services Set-Aside Program $117,561
93.592 Family Violence Prevention and Services/discretionary $100,454