Finding Text
Federal Agency: United States Department of Health and Human Services
Federal Program: Grants for New and Expanded Services under the Health Center Program
Federal Assistance Listing Number 93.527 Federal Award Year: 2022-2023
Criteria or specific requirement – Suspension and debarment (2 CFR 180) Nonfederal entities are
prohibited from contracting with or making subawards under covered transactions to parties that are
suspended, debarred, or otherwise excluded from or ineligible for participation in federal
assistance programs or activities.
Condition – The Organization was unable to provide evidence vendors used in covered transactions
were not suspended, debarred, or otherwise excluded.
Cause – The Organization did not have adequate controls and procedures in place relating to
suspension and debarment requirements under the Uniform Guidance.
Effect or Potential Effect – We were unable to determine whether the Organization
complied with the compliance requirement. The Organization may enter into covered
transactions with vendors who have become suspended, debarred, or otherwise excluded.
Questioned Costs – None
Context – The Organization was unable to provide a detailed expenditure listing by vendor
to test compliance with suspension and debarment.
Identification as a Repeat Finding– Not a repeat finding.
Recommendation – The Organization should incorporate internal controls over compliance with the
suspension and debarment compliance requirement, including monitoring vendors against the
exclusions list.
Views of Responsible Officials and Planned Corrective Actions – Management
acknowledges the audit finding related to suspension and debarment compliance under Federal
Program: Grant for New and Expanded Services under the Health Center Program (Federal Assistance
Listing Number 93.527; Federal Award Year 2022-2023). We are committed to implementing corrective
measures to address the identified deficiencies and ensure full compliance with 2 CFR 180
regulations.
Corrective Actions Taken:
1. Established & Implemented Suspension & Debarment Verification Procedures:
- A new accounting system with a centralized procurement tracking system has been
implemented and is currently being used. Bill.com is used to record vendor information
including Sam.gov vendor eligibility documentation.
- All vendors are verified using Sam.gov. and documentation is kept in the electronic
vendor file in Bill.com. This process was implemented in March 2024 and is ongoing.
2. Monitoring
- The Finance team conducts annual self-assessments to ensure vendor eligibility
documentation is current and up to date. Any vendors that are suspended, debarred, or
otherwise excluded from federal assistance programs are reported to the Executive team to
ensure compliance.
We believe that these actions will significantly mitigate the risks associated with the
identified conditions and strengthen our internal control environment and align our
practices with federal regulations.