Finding 499121 (2023-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-27
Audit: 321903
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: BCHN failed to check the System for Award Management (sam.gov) for suspended or debarred employees and vendors before hiring.
  • Impacted Requirements: This violates 2 CFR 200.214, which mandates checks to prevent federal funds from going to ineligible parties.
  • Recommended Follow-Up: Implement a formal policy for HR to verify sam.gov status before hiring and conduct annual checks, retaining evidence of compliance.

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.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 499114 2023-002
    Significant Deficiency Repeat
  • 499115 2023-003
    Significant Deficiency
  • 499116 2023-004
    Significant Deficiency
  • 499117 2023-002
    Significant Deficiency Repeat
  • 499118 2023-003
    Significant Deficiency
  • 499119 2023-004
    Significant Deficiency
  • 499120 2023-002
    Significant Deficiency Repeat
  • 499122 2023-004
    Significant Deficiency
  • 499123 2023-002
    Significant Deficiency Repeat
  • 499124 2023-003
    Significant Deficiency
  • 499125 2023-004
    Significant Deficiency
  • 1075556 2023-002
    Significant Deficiency Repeat
  • 1075557 2023-003
    Significant Deficiency
  • 1075558 2023-004
    Significant Deficiency
  • 1075559 2023-002
    Significant Deficiency Repeat
  • 1075560 2023-003
    Significant Deficiency
  • 1075561 2023-004
    Significant Deficiency
  • 1075562 2023-002
    Significant Deficiency Repeat
  • 1075563 2023-003
    Significant Deficiency
  • 1075564 2023-004
    Significant Deficiency
  • 1075565 2023-002
    Significant Deficiency Repeat
  • 1075566 2023-003
    Significant Deficiency
  • 1075567 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $6.63M
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $574,003
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $413,327