Finding Text
Criteria: The Organization is required to comply with the Health and Human Services guidelines from 2 CFR parts 180 & 376 and 31 U.S.C. 3321 regarding suspension and debarment compliance requirements. Condition and Context: The Organization did not have proper internal controls in place over compliance on suspension and debarment in accordance with their Health and Human Services contract for all of fiscal year 2024. Cause: The Organization was unaware of the suspension and debarment compliance requirement as they relate to their staff working on the respective contract during all of fiscal year 2024. Effect or Potential Effect: The potential effect is that the Organization could have suspended or debarred employees working under a federal contract. A sampling of 11 employees tested during the audit did not result in any employees being noted as suspended or debarred that worked under the contract during the year ended June 30, 2024. Questioned Costs: N/A Repeat Finding: Repeat finding of 2023-001 Recommendation: Management established internal controls to ensure that the suspension and department requirements were adhered to, however, this did not occur until midway through fiscal year 2024. Management should maintain the controls now put into place moving forward. Views of Responsible Officials: We acknowledge the deficiency highlighted in your report regarding the lack of proper internal controls over compliance with suspension and debarment regulations, particularly in relation to our Health and Human Services contract. We understand the significance of adhering to these requirements and recognize the potential risks associated with noncompliance. The cause of this deficiency, as identified, stems from the organization's unawareness of the suspension and debarment compliance requirement in relation to staff working on the respective contract. We appreciate your thoroughness in identifying the root cause of the issue. In response to your recommendation, management has established a process and policy to ensure full compliance with suspension and debarment requirements. CARITAS will search for individuals listed on the government site on a quarterly basis and will retain notes on the search in a folder to document the review.
Status: Management properly established internal controls around suspension and debarment as of March 2024.