Finding Text
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.