Finding 499518 (2023-001)

Finding 2023-001 Significant Deficiency in Internal Controls over Compliance related to suspension and debarment. Federal Agency: National Institutes of Health Program Title: Human Genome Research Assistance Listing Number: 93.172 Award Number: 5UM1HG009444-04 Award Period: February 1, 2020 through January 31, 2023 Federal Agency: National Institutes of Health Program Title: Cancer Biology Research Assistance Listing Number: 93.396 Award Number: 1R01CA262577-0A Award Period: September 1, 2022 through August 31, 2023 Federal Agency: National Institutes of Health Program Title: Aging Research Assistance Listing Number: 93.866 Award Number: 4R00AG061216-03 Award Period: February 1, 2022 through January 31, 2023 Criteria Procurement requirements contained in Title 2 US Code of Federal Regulations Part 180 - OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (as codified by DHHS in 45 CFR 75) requires a non-Federal entity to ensure that covered transactions are not entered into with vendors that are disqualified by the U.S. Government. Additionally, the Institute’s procurement policy requires that evidence be retained to support that the third party is not listed as suspended or debarred. Condition/Context for Evaluation Our audit testing of procurement transactions included three procurements out of three tested that did not include adequate documentation to support that that the Institute had verified that the third party was not listed as suspended or debarred by the U.S. Government. The Institute maintains that the search was performed and that it was verified that that third party was neither listed as suspended nor debarred by the U.S. Government before entering into the transaction; however, documentation supporting the results of the search as required by the Institute’s procurement policy was not retained. The sample was not a statistical sample. Effect or Potential Effect The effect is that covered transactions could be entered into with parties for which the Institute does not have documentation supporting that the parties were neither suspended or debarred. Questioned Costs Not applicable. Cause The Institute did not follow their documented procurement policy over suspension and debarment to ensure that documentation was retained to support the Institute’s verification was performed confirm that third parties were not listed as suspended or debarred by the U.S. Government when entering into covered transactions. Repeat Finding Findings 2023-001 is not a repeat finding. Recommendation We recommend that the Institute implement the necessary internal controls to ensure that the documented policy over suspension and debarment is followed. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.