Finding Text
Finding 2021-005: Procurement, Suspension and Debarment -
Material Weakness
Grantor: U.S. Department of Health and Human
Services
Federal Program Names: Health Center Program Cluster:
Health Center Program (Community Health
Centers, Migrant Health Centers, Health
Care for the Homeless, and Public Housing
Primary Care)
COVID-19 Health Center Program
(Community Health Centers, Migrant Health
Centers, Health Care for the Homeless, and
Public Housing Primary Care)
Grants for New and Expanded Services
under the Health Center Program
Federal Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number and Year: H80CS26638 - 2020 and 2021,
H8DCS35487 - 2020, H8CCS34364 - 2020,
H8ECS38373 - 2020, and H8F40829 - 2021
Criteria
In accordance with §200.318(a), General Procurement Standards, a non-federal entity must use its
own documented procurement procedures which reflect applicable state, local, and tribal laws and
regulations, provided that the procurements conform to applicable federal law and the standards
identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal
entity must maintain records sufficient to detail the history of the procurement.
In addition, in accordance with §200.213 and §180.300, non-federal entities cannot enter into
awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise
excluded from or ineligible for participation in federal assistance programs or activities.
Condition
There was no evidence that the Center reviewed vendors for suspension and debarment in
accordance with the Uniform Guidance requirements.
Cause
The Center did not have adequate controls to illustrate review of vendors for any suspensions or
debarment.
Effect
The Center may procure goods and services from vendors that have been suspended or debarred
from doing business with the federal government.
Questioned Costs
None.
Context
We selected a sample of four vendors for suspension and debarment for testing. For all four
vendors tested, management did not provide adequate supporting documentation for the review
and approval of each vendor as to whether they have been suspended or debarred.
Identification of Repeat Finding
Yes, see finding 2020-005.
Recommendation
The Center should develop a written procedure to review all vendors and individuals in accordance
with the Uniform Guidance requirements for suspension and debarment. This procedure should be
reviewed with the appropriate staff to ensure compliance with the requirement.
Views of Responsible Officials
Management and the Board of Directors agree with the finding and will implement additional
controls to ensure vendors are being reviewed for suspension and debarment and there is evidence
of a formal review being performed.