Core Issue: Lack of written suspension and debarment policies and procedures, leading to unverified contractor and subrecipient statuses.
Impacted Requirements: Non-federal entities must verify that contractors and subrecipients are not suspended or debarred to comply with federal regulations.
Recommended Follow-Up: Establish and document written policies and procedures for suspension and debarment verification to mitigate risks.
Finding Text
2023-02-Written suspension and debarment policies and procedures have
not been established, and suspension and debarment verifications were not
documented
Finding type- Material weakness in internal control over suspension and
debarment.
Criteria- Non-federal entities are prohibited from contracting with or
making subawards under covered transactions to parties that are suspended
or debarred. Pass-through entities must establish written policies and
procedures for suspension and debarment verification of contractors and
subrecipients.
Condition- Written suspension and debarment policies and procedures have
not been established. Suspension and debarment contractor and subrecipient
verifications were not documented. Based upon our review of Exclusion
Listing on Sam.gov none of the sub-awards to subrecipients were suspended
or debarred.
Effect of Condition- This condition could increase the risk of federal
funding being given to suspended or debarred contractors and subrecipients.
.
Recommendation- We recommend written policies and procedures be
established for suspension and debarment verification. We recommend all
suspension and debarred verifications be documented and filed.
. View of Responsible Officials- RHPHF agrees with the findings and the auditor’s
recommendations above.
Corrective Action Plan
RHPHF will establish a policy detailing procedures for verifying sub recipient eligibility for receiving qualifying federal funds and verifying the potential status of suspension or debarment of potential sub recipients.
--RHPHF will outline how eligibility, suspension and debarment verifications will be documented.
--RHPHF will evaluate if changes or additions to contracts should be made to require sub recipients to disclose or update as to their eligibility status for use of qualifying federal funds.