Finding Text
Federal Agency: U.S. Department of Health and Human Services Federal Program: Consolidated Health Centers Grant AL Number: 93.224 & 93.527 Award Period: 1/1/22 - 12/31/22 Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance Criteria or Specific Requirement 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition and Context During our testing over suspension and debarment, we noted the two instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor. Effect The auditor noted instances of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors. Questioned Costs None identified. Cause The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transactions. Recommendation We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors. Views of Responsible Officials The Organization will retrain staff to follow the current Procurement Policy. The current policy does state: ?Federal exclusions list: the SCCC staff initiating the purchase or department which is seeking purchase from a particular vendor shall screen the vendor name against the Office of Inspector General?s (OIG) List of Excluded Individuals and Entities http://oig.hhs.gov/exclusions/exclusions_list.asp and the General Service Administration?s (GSA) Excluded Parties List System https://www.sam.gov/portal/SAM/#1 (together referred to as the Excluded Lists).