Finding 498474 (2023-002)

Evaluating Potential Contractor for Debarment and Suspension Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086491-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal control and material noncompliance with laws and regulations Repeat Finding: No Criteria: A nonfederal entity must have adequate procedures in place to verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6). Condition: During procurement testing of the Certified Community Behavior Health Clinic Expansion Grant, we noted that the Board did not have documentation that sam.gov was reviewed to ensure the consultant utilized was not suspended or debarred. Identification of How Likely Questioned Costs Were Computed: N/A Known Questioned Costs: None. Subsequently, the sam.gov website was reviewed to ensure that the contractors were not suspended or debarred. Context: The consultant utilized for the Certified Community Behavior Health Clinic Expansion Grant project was not evaluated. Cause/Effect: The Board currently has a process for suspension and debarment for direct service providers only, and did not have controls in place to comply with suspension and debarment evaluation requirements for the Certified Community Behavioral Health Clinic Expansion Grant or other federal funds outside of direct service providers. Recommendation: We recommend the Board implement adequate controls to ensure verification of debarment, suspension, or exclusion takes place before entering into covered transactions. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.