Finding Text
2022 ? 001 Federal Agency: Department of Health and Human Services Federal Program Name: Maternal, Infant, and Early Childhood Home Visiting Grant Program Listing Number: 93.870 Federal Award Identification Number and Year: EVVMPGHM8QB3 Pass-Through Agency: Connecticut Office of Early Childhood Pass-Through Number: 12060-OEC64860-22683 Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov Home, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: There was no documentation maintained to show that verification was performed before EdAdvance entered into a transaction with subrecipients. Questioned costs: None Context: We reviewed 2 out of the 4 subrecipients of the grant. Per discussion with management, they verbally confirmed with subrecipients that they are not suspended or debarred and subsequently confirmed that they are not listed under the Excluded Parties List System. However, there was no documentation showing that the verification was performed before EdAdvance entered into a transaction with subrecipients. Cause: Improper monitoring controls of review procedures and documentation policies Effect: There is no evidence that the verification was performed before entering into a transaction with subrecipients. Repeat Finding: No