Finding 516680 (2024-006)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2024-12-23

AI Summary

  • Core Issue: The Organization lacks effective internal controls to ensure compliance with suspension and debarment requirements, risking engagement with ineligible vendors.
  • Impacted Requirements: Noncompliance with 45 CFR 75.213 due to inadequate monitoring of existing vendors and lack of documentation for compliance checks.
  • Recommended Follow-Up: Develop a formal policy for vendor monitoring, enhance documentation practices, and provide training to staff on compliance procedures.

Finding Text

Health Center Program Cluster – Assistance Listing Nos. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. 6 H80CS00751-22-03, April 1, 2023 – March 31, 2024 Award No. 4 H8GCS47984-01-01, December 1, 2022 – December 31, 2023 Award No. 6 H8FCS41089‐01‐03, April 1, 2021 – March 31, 2024 Criteria or Specific Requirement – Suspension and Debarment – 45 CFR 75.213 Condition – The Organization’s internal controls over compliance do not appear to be designed to prevent or detect and timely correct noncompliance with the suspension and debarment compliance requirements. Questioned Costs – None Context – The Organization’s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded do not include monitoring of existing vendors. Additionally, a sample of two vendors was tested out of a population of 7 vendors with expenditures exceeding $25,000 during the year. Samples were not, and were not intended to be, statistically valid. Documentation was not maintained to support management’s initial verification that one of the vendors selected for testing was not suspended, debarred, or otherwise excluded prior to entering into covered transaction. The vendor was not suspended, debarred, or otherwise excluded when checked during the audit. Effect – The Organization may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded since becoming a vendor of the Organization. Additionally, documentation was not maintained to support the internal controls over compliance in place. Cause – The Organization’s suspension and debarment procedures are not formalized into a policy to support compliance with Uniform Guidance. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should incorporate internal controls over compliance with the suspension and debarment compliance requirement, including a policy for monitoring existing vendors against the exclusions list, into its formal policies. The Organization should also provide education and training on the policy to further support compliance. Views of responsible officials and planned corrective actions – The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 516671 2024-003
    Significant Deficiency
  • 516672 2024-003
    Significant Deficiency
  • 516673 2024-004
    Significant Deficiency
  • 516674 2024-005
    Significant Deficiency
  • 516675 2024-005
    Significant Deficiency
  • 516676 2024-005
    Significant Deficiency
  • 516677 2024-005
    Significant Deficiency
  • 516678 2024-006
    Significant Deficiency
  • 516679 2024-006
    Significant Deficiency
  • 516681 2024-006
    Significant Deficiency
  • 516682 2024-007
    Material Weakness
  • 516683 2024-007
    Material Weakness
  • 516684 2024-008
    Significant Deficiency
  • 516685 2024-008
    Significant Deficiency
  • 516686 2024-008
    Significant Deficiency
  • 516687 2024-008
    Significant Deficiency
  • 1093113 2024-003
    Significant Deficiency
  • 1093114 2024-003
    Significant Deficiency
  • 1093115 2024-004
    Significant Deficiency
  • 1093116 2024-005
    Significant Deficiency
  • 1093117 2024-005
    Significant Deficiency
  • 1093118 2024-005
    Significant Deficiency
  • 1093119 2024-005
    Significant Deficiency
  • 1093120 2024-006
    Significant Deficiency
  • 1093121 2024-006
    Significant Deficiency
  • 1093122 2024-006
    Significant Deficiency
  • 1093123 2024-006
    Significant Deficiency
  • 1093124 2024-007
    Material Weakness
  • 1093125 2024-007
    Material Weakness
  • 1093126 2024-008
    Significant Deficiency
  • 1093127 2024-008
    Significant Deficiency
  • 1093128 2024-008
    Significant Deficiency
  • 1093129 2024-008
    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) $1.74M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $92,685
21.027 Coronavirus State and Local Fiscal Recovery Funds $81,304
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated and State Partnership Marketplaces $35,027
93.307 Minority Health and Health Disparities Research $13,411
93.268 Immunization Cooperative Agreements $685