Finding 564241 (2024-002)

2024 – 002 Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Sexually Transmitted Diseases (STD) Prevention and Control Grants Assistance Listing Number: 93.977 Federal Award Identification Number and Year: Pass-Through Agency: Texas Department of State and Health Services Pass-Through Number(s): HHS000031000001; HHS001201000001 Award Period: 8/1/18-12/31/23; 1/1/24-8/31/25 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: Suspension and debarment check was not completed for one of four vendors tested and was not completed timely for the other three tested vendors. Questioned costs: None Context: A corrective action plan (CAP) was implemented to address prior audit finding, however due to the timing of the prior year audit and CAP, the improvements were not yet implemented until partially through the current audit period. Cause: Controls were insufficient to ensure suspension and debarment check was performed on all vendors with covered transactions prior to implementation of prior year audit's CAP. Effect: Could have entered into covered transactions with suspended or debarred vendors. Repeat Finding: 2023-001 Recommendation: CLA recommends Cardea update policies to ensure that Uniform Guidance requirements are met to perform and document suspension and debarment checks are being done. Views of responsible officials: There is no disagreement with the audit finding.