Finding 565387 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-06-19
Audit: 359249
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The Organization did not retain evidence of vendor checks against the suspension and debarment list, despite having policies in place.
  • Impacted Requirements: Compliance with 2 CFR 200.318 and 2 CFR 200.214 regarding documented procurement procedures and vendor eligibility.
  • Recommended Follow-Up: Update policies to ensure proper documentation of suspension and debarment checks is consistently maintained.

Finding Text

Procurement, Suspension and Debarment Federal agency: U.S. Department of Health and Human Services Program: Continuation of the National Evaluations System for Health Technology Coordinating Center Assistance listing number: 93.103 Federal award identification number and year: • 2U01FD006292-06 2024 • 3U01FD006292-06S1 2023 Criteria: 2 CFR 200.318 states non-federal entities must have and use documented procurement procedures that conform to 2 CFR 200.317 through 200.327. 2 CFR 200.214 states non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Order 12549 and 12689, 2 CFR Part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 200 requires adequate documentation of compliance with 2 CFR 200.214. Condition and context: The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed however the evidence of the search on sam.gov was not retained. A sample of five vendors with a total contract value of $8,528,526 was selected from a population of twelve. Cause: The Organization’s management did not retain evidence of compliance with the above criteria regarding suspension and debarment due to oversight. Effect: The Organization’s documentation was lacking evidence of tracking vendors for suspension and debarment. Questioned costs: None Repeat finding: No Recommendation: We recommend management updates its policies and procedures to ensure adequate supporting documentation of suspension and debarment verification is maintained. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 565386 2024-001
    Significant Deficiency
  • 1141828 2024-001
    Significant Deficiency
  • 1141829 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.103 Food and Drug Administration Research $11.09M