FAC Explorer

Finding 499530 (2023-011)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-30
Audit: 322389
Organization: Hennepin County Minnesota (MN)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The county hospital lacks effective internal controls to ensure compliance with suspension and debarment requirements for federal grants.
  • Impacted Requirements: Non-compliance with 45 CFR 75.303(a) and 45 CFR 75.213, which mandate verification of vendor eligibility for federal funding.
  • Recommended Follow-Up: Implement checks against SAM.gov for contractors and conduct annual reviews of vendor eligibility, maintaining documentation of these processes.

Finding Text

Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Program: Congressional Directives (ALN 93.493) Pass-through Entity: N/A Federal Assistance Identification Number or Pass-Through Number: CE146419 Federal Award Year: Year ended December 31, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Other Matter Compliance Finding Criteria: 45 CFR 75.303(a) requires that each non-Federal entity must "Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award…”. 45 CFR 75.213 requires that “Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR parts 180 and 376. These regulations 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: The county hospital does not have effective internal controls over the suspension and debarment requirement for the Congressional Directives program. In addition, there was no evidence that the county hospital had verified that entities receiving more than $25,000 in federal grant funds were not suspended or debarred prior to providing them with federal funds. Cause: For most specialized medical equipment purchased under this grant, the department identifying the need for the equipment is also responsible for selecting the vendor. These personnel do not appear to receive training in the requirements related to suspension and debarment for federally funded projects. Effect: While not found during our testing, the lack of controls over this requirement increases the possibility that contracts could be awarded to vendors that are ineligible to provide goods and services under federally funded grants. Context: For all of the procurements selected for testing that were covered transactions, documentation was not maintained that could provide evidence that the county hospital had performed the required verifications. Out of 11 covered transactions, 8 were selected for testing. The sample sizes were based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Questioned Costs: None Repeat Finding?: No Recommendation: We recommend that when entering into a contract that relates to a covered transaction that the county hospital either search for the contractor in the list at SAM.gov, or obtain certification from the potential vendor that they are not excluded from participation in federally funded procurements. Additionally, on an annual basis we recommend that the county hospital compares the vendor and employee master file to the excluded parties list at SAM.gov to ensure there are not any on the list that impact the county hospital’s current contracts. The county hospital should retain documentation demonstrating each of these internal control activities was performed timely. View of responsible officials of the auditee: Hennepin Healthcare System Inc. has reviewed and agrees with the finding and recommendation.

Corrective Action Plan

Subject: Hennepin County’s 2023 Corrective Action Plan Finding# 2023-011 Suspension and Debarment Program: Congressional Directives (ALN 93.493) Type of Finding: Material Weakness in Internal Control over Compliance; Other Matter Compliance Finding Condition: The county hospital does not have effective internal controls over the suspension and debarment requirement for the Congressional Directives program. In addition, there was no evidence that the county hospital had verified that entities receiving more than $25,000 in federal grant funds were not suspended or debarred prior to providing them with federal funds. Hennepin County’s Corrective Action Planned in Response to Finding: Hennepin Healthcare System, Inc. (HHS) implemented procedures in its Peoplesoft system to document entities receiving more than $25,000 in federal grant funds were not suspended or debarred prior to providing them with federal funds. Hennepin County Employee Responsible for the CAP: Mark Willmert Planned Completion Date for CAP: December 31, 2024

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 499524 2023-005
    Significant Deficiency Repeat
  • 499525 2023-006
    Significant Deficiency Repeat
  • 499526 2023-007
    Material Weakness Repeat
  • 499527 2023-008
    Significant Deficiency Repeat
  • 499528 2023-009
    Significant Deficiency
  • 499529 2023-010
    Significant Deficiency
  • 499531 2023-012
    Material Weakness
  • 499532 2023-013
    Material Weakness
  • 499533 2023-004
    Significant Deficiency
  • 499534 2023-004
    Significant Deficiency
  • 499535 2023-004
    Significant Deficiency
  • 499536 2023-004
    Significant Deficiency
  • 499537 2023-004
    Significant Deficiency
  • 1075966 2023-005
    Significant Deficiency Repeat
  • 1075967 2023-006
    Significant Deficiency Repeat
  • 1075968 2023-007
    Material Weakness Repeat
  • 1075969 2023-008
    Significant Deficiency Repeat
  • 1075970 2023-009
    Significant Deficiency
  • 1075971 2023-010
    Significant Deficiency
  • 1075972 2023-011
    Material Weakness
  • 1075973 2023-012
    Material Weakness
  • 1075974 2023-013
    Material Weakness
  • 1075975 2023-004
    Significant Deficiency
  • 1075976 2023-004
    Significant Deficiency
  • 1075977 2023-004
    Significant Deficiency
  • 1075978 2023-004
    Significant Deficiency
  • 1075979 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $79.65M
93.563 Child Support Enforcement $21.24M
93.658 Foster Care_title IV-E $19.59M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $15.93M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $8.15M
20.205 Highway Planning and Construction $7.20M
93.667 Social Services Block Grant $6.84M
93.914 Hiv Emergency Relief Project Grants $6.41M
14.239 Home Investment Partnerships Program $4.63M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $4.14M
93.575 Child Care and Development Block Grant $3.25M
14.905 Lead Hazard Reduction Demonstration Grant Program $2.31M
93.958 Block Grants for Community Mental Health Services $1.76M
14.267 Continuum of Care Program $1.76M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.67M
93.493 Congressional Directives $1.67M
93.268 Immunization Cooperative Agreements $1.50M
93.297 Teenage Pregnancy Prevention Program $1.44M
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $1.43M
17.258 Wia Adult Program $1.28M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $1.23M
97.042 Emergency Management Performance Grants $1.05M
93.247 Advanced Nursing Education Grant Program $955,271
93.889 National Bioterrorism Hospital Preparedness Program $844,047
97.067 Homeland Security Grant Program $790,426
93.498 Provider Relief Fund $774,769
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $769,329
93.788 Opioid Str $724,378
93.994 Maternal and Child Health Services Block Grant to the States $697,212
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $610,652
93.253 Poison Center Support and Enhancement Grant $608,770
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $596,061
16.833 National Sexual Assault Kit Initiative $549,564
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $525,697
14.913 Healthy Homes Production Program $507,287
17.278 Wia Dislocated Worker Formula Grants $474,134
93.069 Public Health Emergency Preparedness $438,081
16.738 Edward Byrne Memorial Justice Assistance Grant Program $436,972
17.259 Wia Youth Activities $429,367
21.027 Coronavirus State and Local Fiscal Recovery Funds $400,725
14.276 Youth Homelessness Demonstration Program $398,351
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $375,462
93.940 Hiv Prevention Activities_health Department Based $368,567
14.231 Emergency Solutions Grant Program $357,697
93.583 Refugee and Entrant Assistance_wilson/fish Program $348,145
16.575 Crime Victim Assistance $340,992
93.590 Community-Based Child Abuse Prevention Grants $327,518
93.150 Projects for Assistance in Transition From Homelessness (path) $318,574
16.753 Congressionally Recommended Awards $271,650
95.001 High Intensity Drug Trafficking Areas Program $265,969
16.741 Dna Backlog Reduction Program $258,283
93.435 Innovative State and Local Public Health Strategies to Prevent and Manage Diabetes and Heart Disease and Stroke- $234,832
16.582 Crime Victim Assistance/discretionary Grants $226,061
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $178,663
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $178,430
16.922 Equitable Sharing Program $172,687
93.645 Stephanie Tubbs Jones Child Welfare Services Program $169,269
93.800 Organized Approaches to Increase Colorectal Cancer Screening $161,808
93.924 Ryan White Hiv/aids Dental Reimbursement and Community Based Dental Partnership Grants $147,799
93.235 Affordable Care Act (aca) Abstinence Education Program $140,776
14.218 Community Development Block Grants/entitlement Grants $139,939
93.344 Research, Monitoring and Outcomes Definitions for Vaccine Safety $126,207
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $126,020
93.136 Injury Prevention and Control Research and State and Community Based Programs $126,019
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $114,830
16.838 Comprehensive Opioid Abuse Site-Based Program $101,333
93.556 Promoting Safe and Stable Families $94,926
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $93,670
93.566 Refugee and Entrant Assistance_state Administered Programs $90,983
10.580 Supplemental Nutrition Assistance Program, Process and Technology Improvement Grants $88,023
93.558 Temporary Assistance for Needy Families $82,203
93.270 Adult Viral Hepatitis Prevention and Control $73,776
17.277 Workforce Investment Act (wia) National Emergency Grants $73,622
93.251 Early Hearing Detection and Intervention $67,759
93.092 Affordable Care Act (aca) Personal Responsibility Education Program $65,982
93.959 Block Grants for Prevention and Treatment of Substance Abuse $65,206
93.659 Adoption Assistance $64,143
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $60,819
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $57,971
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $55,705
93.917 Hiv Care Formula Grants $54,276
21.023 Emergency Rental Assistance Program $53,093
21.032 Local Assistance and Tribal Consistency Fund $50,000
97.039 Hazard Mitigation Grant $44,137
10.555 National School Lunch Program $41,313
97.012 Boating Safety Financial Assistance $36,071
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $34,576
10.553 School Breakfast Program $29,207
93.008 Medical Reserve Corps Small Grant Program $26,250
93.747 Elder Abuse Prevention Interventions Program $23,509
93.103 Food and Drug Administration_research $21,055
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $19,979
93.767 Children's Health Insurance Program $13,006
90.404 2018 Hava Election Security Grants $11,714
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $8,000
84.002 Adult Education - Basic Grants to States $7,633
93.899 Minority Hiv/aids Fund (mhaf) $5,630
93.945 Assistance Programs for Chronic Disease Prevention and Control $5,241
20.616 National Priority Safety Programs $2,471
84.181 Special Education-Grants for Infants and Families $2,100
93.090 Guardianship Assistance $1,455
20.600 State and Community Highway Safety $1,047