Finding 401447 (2023-001)

Significant Deficiency

Requirement

Questioned Costs

Year

2023

Accepted

2024-06-21

Audit: 309552

Organization: Community Mental Health Services of Livingston County (MI)

Auditor: Roslund Prestage & Company PC

AI Summary

Core Issue: The contract for the Supportive Housing Program did not verify if the vendor was suspended or debarred, violating compliance regulations.
Impacted Requirements: This oversight breaches 2 CFR 200.214 and 2 CFR part 180, which mandate checks on vendor eligibility for federal assistance.
Recommended Follow-Up: Update contract language to include a certification clause ensuring vendors are not suspended or debarred.

Finding Text

2023-001 – Suspension and Debarment Finding Type: Significant Deficiency in internal control over compliance Program: ALN 14.267 – Supportive Housing Program Criteria: As required by 2 CFR 200.214, Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities Condition: The vendor used for this grant was not checked for suspension and debarment prior to execution of the contract. Also, the contract did not include certification that the vendor was not suspended or debarred. Cause: Management oversight. Questioned Cost: None. Recommendation: We recommend that the CMHSP update contract language to include certification that vendor is not suspended or debarred. View of Responsible Official: Management is in agreement with this recommendation

Corrective Action Plan

Community Mental Health Services of Livingston County Single Audit Report: Corrective Action Plan Year ended September 30, 2023 Finding 2023-001- Suspension and Debarment Requirement: As required by 2 CFR 200.214, Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Finding: Vendor was not checked for suspension and debarment prior to execution of the contract. Also, the contract did not include certification that vendor was not suspended or debarred. Questioned Cost: None. Recommendation: Contract language should be updated to include certification that vendor is not suspended or debarred. Corrective Action Plan LCCMHA is committed to addressing the concern raised by RPC and agrees with the above recommendation. The Contract Manager will modify existing contract language to include certification that vendors are not suspended or debarred. This change will be implemented for fiscal year 2025 commencing 10/01/24.

Other Findings in this Audit

401448 2023-001

Significant Deficiency
977889 2023-001

Significant Deficiency
977890 2023-001

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
93.778	Medical Assistance Program	$204,715
14.267	Continuum of Care Program	$48,013
93.959	Block Grants for Prevention and Treatment of Substance Abuse	$16,872
93.788	Opioid Str	$9,442
93.958	Block Grants for Community Mental Health Services	$2,682