Finding Text
Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Federal Program: Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects Assistance Listing: 93.185 Grant Identification Numbers: NH231P922569 and NH231P922569C5 ? COVID-19 Grant Period: 2022 Finding 2022-002: Significant Deficiency ? Procurement/Suspension and Debarment Criteria: Non-federal entities are required to verify suspension and debarment per 2 CFR 180.300. The debarment and suspension procedures are intended to prevent waste, fraud and abuse in federal procurement and non-procurement actions. Debarment or suspension of an organization or individual excludes that entity or individual from doing business with the Federal Government. These exclusions are intended to ensure that only responsible entities or individuals participate in contracts and financial assistance awards with the Federal Government. Condition: During our testing for compliance over procurement, we noted that procurements anticipated to be $25,000 or more in aggregate did not have documentation showing controls over the search for suspension and debarment of contractors. Context: Procurements that were small purchases lacked documentation of researching contractors for debarment, suspension, or other exclusions from or ineligibility for participating in Federal assistance programs or activities. Statistical sampling was not used, however, sampling methods were applied using AICPA guidance. Effect: There is a possibility that the Organization enters into a contract with a party that has been debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: Lack of effective policy and formal documentation to govern the procurement process around small purchases. Questioned costs: There were no questioned costs related to this finding. Repeat finding: This is not a repeat finding. Auditor?s recommendation: We recommend that the Organization update its procurement policy to address suspension and debarment procedures. We recommend that the following be performed on covered procurement and non-procurement transactions to verify that the other person/entity is not suspended or debarred. a.) Checking SAM.gov exclusions; or b.) Collecting a certification from that person or entity; or c.) Adding a clause or condition to the covered transaction. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.