Finding 556184 (2021-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2021
Accepted
2025-04-29
Audit: 354872
Organization: Island Health, Inc. (MA)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Center failed to check vendors for suspension and debarment as required by federal guidelines.
  • Impacted Requirements: Non-compliance with §200.318 and §200.213, risking procurement from ineligible vendors.
  • Recommended Follow-Up: Establish a written procedure for vendor reviews and ensure staff are trained on compliance.

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.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 556177 2021-003
    Material Weakness Repeat
  • 556178 2021-004
    Material Weakness Repeat
  • 556179 2021-005
    Material Weakness Repeat
  • 556180 2021-006
    Material Weakness Repeat
  • 556181 2021-007
    Material Weakness Repeat
  • 556182 2021-003
    Material Weakness Repeat
  • 556183 2021-004
    Material Weakness Repeat
  • 556185 2021-006
    Material Weakness Repeat
  • 556186 2021-007
    Material Weakness Repeat
  • 556187 2021-003
    Material Weakness Repeat
  • 556188 2021-004
    Material Weakness Repeat
  • 556189 2021-005
    Material Weakness Repeat
  • 556190 2021-006
    Material Weakness Repeat
  • 556191 2021-007
    Material Weakness Repeat
  • 1132619 2021-003
    Material Weakness Repeat
  • 1132620 2021-004
    Material Weakness Repeat
  • 1132621 2021-005
    Material Weakness Repeat
  • 1132622 2021-006
    Material Weakness Repeat
  • 1132623 2021-007
    Material Weakness Repeat
  • 1132624 2021-003
    Material Weakness Repeat
  • 1132625 2021-004
    Material Weakness Repeat
  • 1132626 2021-005
    Material Weakness Repeat
  • 1132627 2021-006
    Material Weakness Repeat
  • 1132628 2021-007
    Material Weakness Repeat
  • 1132629 2021-003
    Material Weakness Repeat
  • 1132630 2021-004
    Material Weakness Repeat
  • 1132631 2021-005
    Material Weakness Repeat
  • 1132632 2021-006
    Material Weakness Repeat
  • 1132633 2021-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $1.03M
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care $600,236
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $29,517
93.461 Covid-19-Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $12,720