Finding Text
Finding 2023-003 - Procurement and Suspension and Debarment – Significant Deficiency
Name of Federal Agency: U.S. Department of Health and Human Services
Federal Program Name(s): Health Center Program Cluster - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care and COVID-19 - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care and Grants for New and Expanded Services Under the Health Center Program and COVID-19 - Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number(s) and Year(s): H8F4083 - 2021, H8000626 - 2022, H8G48366 - 2022
Criteria
In accordance with 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations. 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
During our audit, we noted that BCHN did not perform a timely check at the System for Award Management Exclusions (sam.gov) to verify whether an employee or a vendor had been suspended or debarred before being hired.
Cause
There is no formal policy in place requiring a check to be performed at sam.gov for prospective employees and vendors.
Effect or Potential Effect
The condition could result in employees or vendors who are suspended or debarred receiving federal funds.
Questioned Costs
None.
Context
Seven exceptions from a statistically valid sample of seven.
Identification as Repeat Finding
No.
Recommendation
We recommend Human Resources (HR) personnel/management perform a check at sam.gov prior to the hire of an employee or vendor to ensure the employee or vendor was not suspended or debarred and retain evidence of that verification. We also recommend a check at sam.gov be done annually thereafter and evidence of that verification be maintained.
Views of Responsible Officials
BCHN will check sam.gov and the Office of Inspector General, to screen all potential employees, contractors/consultants, and vendors, prior to the commencement of their affiliation with BCHN and maintain evidence of the results. BCHN will also screen all employees, contractors, consultants, and vendors on an annual basis thereafter and maintain evidence of the results.