Finding Text
MW2020-007 PROCUREMENT, SUSPENSION AND DEBARMENT (REPEAT FINDING)
(PREVIOUSLY REPORTED AS MW2019-004)
Condition
CUAHSI had a policy in place regarding procurement of which they were unable to provide any
documentation that they complied with the policy. There was no documentation for one payment
made to the Board Member for $15,000. While there were invoices for the remaining amounts,
there was no documentation maintained that showed CUAHSI verified expenses were incurred
from vendors that were not suspended or debarred.
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
Cause
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
CUAHSI is not in compliance with UG requirements, there could be future legal action, the
repayment of funds, loss of reputation and possible suspension or debarment.Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
Current Year Status
This condition still exists for the year ended December 31, 2020. During the completion of the
audit, the auditor noted that CUAHSI failed to maintain and provide the proper records and
support to document their review of vendor files. Such failure led to non-compliance with the
procurement, suspension and debarment policies in accordance with the UG for the year ended
December 31, 2020.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.