Finding 564088 (2024-001)

Item 2024-001 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) FAIN # H8000163, H8F41100 for 2024 - (Significant Deficiency) Criteria: Recipients and subrecipients are subject to the procurement, debarment and suspension 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 an exclusion search for all newly hired employees and new contractors. Statement of condition: During our audit, we noted that certain employees hired in 2024 have no record of an exclusion search conducted. Cause: Inconsistent application of the internal control to ensure compliance with the general suspension and debarment requirements. 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: Two out of four samples tested did not have any exclusion searches on file upon hiring 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: We will ensure that the center's personnel are trained in the exclusion screening, maintain the location of the proper documentation, and conduct regular reviews to ensure the completeness of exclusion search documentation. The center performs background checks but was unable to locate the documents for those two new employees who were terminated but will ensure that we will put control processes in place to make sure we can demonstrate that the exclusion search was conducted.