Finding Text
Compliance with Uniform Guidance - Procurement Suspension and Debarment
Information on Federal Program: Unaccompanied Alien Children (Assistance Listing
No. 93.676) provided by the Department of Health and Human Services.
Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6
state that a non-Federal entity must review that an entity with which it plans to enter into a
covered transaction is not debarred, suspended, or otherwise excluded from participation
in federal award programs.
Condition: During our testing for procurement compliance, it was determined that the
Home did not verify that vendors charged to the major program are not debarred,
suspended, or otherwise excluded from participation in federal award programs.
Questioned Cost: None
Cause: The Home was not aware of the requirement to review an entity’s status.
Effect: The Home is not in compliance with 2 CFR Sections 200.212, 200.318(h), and
180.300 and 48 CFR Section 52.209-6. As a result, the Home could enter into covered
transactions with entities that are debarred, suspended, or otherwise excluded from
participation in federal award programs.
Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to
determine if they are debarred, suspended, or otherwise excluded from participation in
federal award programs. None were noted to be ineligible for participation.
Repeat Finding: Yes
Recommendation: We recommend the Home review and document the verification that
vendors are not debarred, suspended, or otherwise excluded from participation in federal
award programs.
Views of the Responsible Officials and Planned Corrective Actions: This item was
included in the 6/30/22 Report on Compliance for Major Federal Programs which was
finalized in February 2023. The G/L Vendor List was found to contain many inactive
vendors and was modified. Beginning in October 2023, management began sending the
vendor List to EPStaffCheck on a monthly basis. Each vendor is run through OIG (Office
of Inspector General for Excluded Individuals/Entities); OIG_Most_Wanted (Fugitives};
SAM (System for Award Management for excluded parties); SON.Office of Foreign
Assets Control (Specially Designated Nationals) and NY _Medicaid (Exclusion List).