Finding Text
U.S. Department of Health and Human Services, passed through the Curators of the University of Missouri
ALN 93.680 - Medical Student Education
PTE Federal Award No: C00084599-1
Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency
In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
Suspension and debarment checks were not completed for the vendors that received federal funds.
Cause:
Bothwell Regional Health Center did not have suspension and debarment controls in place prior to purchases with the vendors.
Effect or Potential Effect:
Federal funds could be paid to entities that are suspended or debarred.
Questioned Costs: None noted.
Context:
Only one vendor was subject to the suspension and debarment requirement in 2024 and was selected for testing. The Health Center purchased $961,978 in goods/services from this vendor in 2024. During our testing, we noted the vendor utilized by the Health Center was not evaluated for suspension and debarment. Upon subsequent check, the vendor was not suspended or debarred.
Identification of Prior Year Finding: N/A
Recommendation:
Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include vendors, we also recommend the contracts include suspension and debarment language.
View of Responsible Official and Planned Corrective Actions:
Management agrees with the finding and management will implement a control process to ensure that suspension and debarment checks are performed on vendors/contracts funded with grants in 2025.