Finding Text
Section III - Federal Award Findings and Questioned Costs
Finding 2024-001 - Procurement, Suspension and Debarment - Significant Deficiency
Name of Federal Agency: U.S. Department of Agriculture
Federal Program Name: WIC Special Supplemental Nutrition Program for Women, Infants, and Children
Assistance Listing Number: 10.557
Federal Award Identification Number and Year: 244NY704W1003; 2023-2024 and 2024-2025
Name of Pass-through Entity: New York State Department of Health
Criteria
In accordance with §200.213 and §180.300, nonfederal 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
During our testing, we noted that the Center did not perform a timely check at the System for Award Management Exclusions (SAM.gov) to verify whether an employee had been suspended or debarred before being hired.
Cause
The Center did not have adequate policies, procedures, and controls in place to ensure compliance with the suspension and debarment requirements.
Effect or Potential Effect
Failure to timely verify that an employee is not suspended or debarred could result in hiring an employee to work on federal grant programs that is barred from performing work for the U.S. government.
Questioned Costs
None.
Context
For four suspension and debarment samples out of a total of four tested, management did not provide evidence that a check at sam.gov was performed before hiring.
Recommendation
We recommend that the Center establish written suspension and debarment policies and procedures to ensure that the Center is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively.
Views of Responsible Officials
Our current protocol requires conducting SAM.gov exclusion checks on or before the hire date. However, due to recent administrative transition, some records from 2025 and prior were found to be unavailable. To address this gap, we have re-verified SAM.gov checks for all new hires in 2025 and will continue performing monthly exclusion checks moving forward. All SAM.gov results will be stored electronically to ensure ongoing compliance and proper documentation.