Finding 43563 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-02-16
Audit: 44640
Organization: Legacy Medical Care Inc. (IL)

AI Summary

  • Core Issue: Legacy failed to document checks on vendor eligibility regarding suspension and debarment before contracting.
  • Impacted Requirements: Compliance with 2 CFR sections 200.212, 200.318(h), and 180.300, which mandate verification of vendor status.
  • Recommended Follow-up: Implement a process to retain documentation from Sam.gov confirming vendor eligibility prior to contract agreements.

Finding Text

Finding 2022-003 ? Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Grants for New and Expanded Services Under the Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: L1CCS39368-01-00; L2CCS42352-01-00 Award Periods: July 1, 2020 ? June 30, 2021; July 1, 2021 ? June 30, 2023 respectively Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Legacy did not document that Sam.gov was checked prior to entering into a contract with a vendor. Questioned Costs: None. Context: Two (2) of two (2) vendors tested. Cause: Legacy did not create and maintain documentation showing that suspension and debarment had be checked prior to engaging a vendor. Effect: Contracted vendors may be ineligible to receive federal dollars for services performed. Repeat Finding: No. Recommendation: We recommend that Legacy retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. The organization can keep screenshots that Sam.gov was checked or a PDF print out of the web page. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Suspension and Debarment ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend that Legacy retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. The organization can keep screenshots that Sam.gov was checked or a PDF print out of the web page. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? LMC staff will review the OIG exclusions list prior to onboarding or signing contracts with vendors. ? LMC staff will print and retain proof of each review for reporting purposes. Name(s) of the contact person(s) responsible for corrective action: Melissa D?Onorio, CEO, and Emily Faricy, CFO. Planned completion date for corrective action plan: January 15, 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 43562 2022-002
    Significant Deficiency
  • 43564 2022-004
    Significant Deficiency
  • 43565 2022-002
    Significant Deficiency
  • 43566 2022-003
    Significant Deficiency
  • 43567 2022-004
    Significant Deficiency
  • 620004 2022-002
    Significant Deficiency
  • 620005 2022-003
    Significant Deficiency
  • 620006 2022-004
    Significant Deficiency
  • 620007 2022-002
    Significant Deficiency
  • 620008 2022-003
    Significant Deficiency
  • 620009 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $700,039
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $404,756
93.498 Provider Relief Fund $269,820
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated and State Partnership Marketplaces $27,210