Finding 2024.002 – Procurement, Suspension and Debarment
Recommendation
The Center should develop a written procedure to review all vendors in accordance with the Uniform Guidance requirements for suspension and debarment. This procedure should be reviewed with the appropriate staff to ensure compliance with the requirement.
Not a repeat finding
Action Taken
Beginning in FY26, NMH has formally adopted the following policy and procedure to address uniform guidance requirements for suspension and debarment. This policy updates and clarifies the Center’s internal procedures, building upon the initial check process and the sporadic exclusion of monthly suspension and debarment checks conducted in FY24. See policy and procedure below:
NMH POLICY & PROCEDURE FOR UNIFORM GUIDANCE REQUIREMENTS FOR SUSPENSION AND DEBARMENT
To ensure that Newport Mental Health (NMH) is not doing business with vendors who have been suspended or debarred from doing business with the federal government, prior to contracting/purchase, the Vice President of Finance, or designee, will ensure the vendor/contractor is not on the List of excluded Individuals and Entities (LEIE) in the Office of Inspector General (OIG) Exclusion Database before creating a purchase order or making a payment.
Procedures for Accounts Payable:
New vendors or contractors must complete a current W-9 and debarment attestation form.
Accounts Payable will verify that the vendor is not suspended or debarred. If a vendor or contractor is found to be suspended or debarred, Accounts Payable will flag them in NXT. This alert notifies invoice processors that federal funds cannot be used for this vendor. Any NMH Department who detects a suspended or debarred vendor should notify Accounts Payable to ensure proper flagging in the system. Procedures for Ongoing Checks:
The Finance Department will generate a list of all vendors and employees paid with Federal funds and review it monthly against the LEIE using Verify Comply, an OIG Exclusion Search Software. If a vendor is found to be suspended or debarred, the Finance Department will reclassify purchases off the Federal grant and notify Accounts Payable to flag the vendor in NXT. Accounts Payable must keep documentation of each check.
The Vice President of Finance oversees these processes to ensure compliance.