Finding Text
Item 2024-005 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00646-22-03, 2 H80CS005646-23-00, 4 H8GCS48213-01-01, 1 H8LCS51923-01-00 for 2023 and 2024 - (Significant Deficiency)
Criteria:
Recipients and subrecipients are subject to the procurement, suspension and debarment regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. The Center's policy is to conduct a monthly exclusion search for all its employees and contractors and requires that all searches are documented within the personnel file in the Human Resource system.
Statement of condition:
During our audit, we noted that certain employees have no record of an exclusion search conducted during 2024. There were also certain employees for whom an exclusion search was not consistently conducted on a monthly basis.
Cause:
Inconsistent application of the internal control.
Effect:
Failure in implementing the exclusion search raises the risk that salaries of employees who are suspended or debarred may be charged to the program.
Questioned costs:
None
Context:
Five out of forty samples tested did not have any exclusion searches on file during 2024. Three out of forty samples did not have exclusion searches done on a monthly basis in 2024.
Identification as a repeat finding:
This is not a repeat finding.
Recommendation:
We recommend that the Center train its personnel in relation to the exclusion screening and proper documentation thereof and that the Center conduct regular reviews to ensure the completeness of exclusion search documentation.
Management response:
Management agrees with the finding and will be conducting training for its personnel to help ensure the accuracy, completeness and timeliness of exclusion searches.