Finding Text
Criteria: The Organization is required to comply with the Health and Human Services guidelines from 2 CFR parts 180 & 376 and 31 U.S.C. 3321 regarding suspension and
debarment compliance requirements.
Condition and Context: The Organization did not have proper internal controls in place over compliance on suspension and debarment in accordance with their Health and Human
Services contract.
Cause: The Organization was unaware of the suspension and debarment compliance requirement as they relate to their staff working on the respective contract.
Effect or Potential Effect: The potential effect is that the Organization could have suspended or debarred employees working under a federal contract. A sampling of 8 employees tested during the audit did not result in any employees being noted as suspended or debarred that worked under the contract during the year ended June 30, 2023
Questioned Costs: N/A
Repeat Finding: No
Recommendation: Management should establish internal controls to ensure that the suspension and debarment requirements are adhered to.
Views of Responsible Officials: We acknowledge the deficiency highlighted in your report regarding the lack of proper internal controls over compliance with suspension and debarment regulations, particularly in relation to our Health and Human Services contract. We understand the significance of adhering to these requirements and recognize the potential risks associated with non-compliance. The cause of this deficiency, as identified, stems from the organization’s unawareness of the suspension and debarment compliance requirement in relation to staff working on the respective contract. We appreciate your thoroughness in identifying the root cause of the issue. While we are relieved that the sampling conducted during the audit did not reveal any suspended or debarred employees working under the contract during the year ended June 30, 2023, we understand the importance of establishing robust internal controls to prevent such occurrences in the future. In response to your recommendation, management has established a process and policy to ensure full compliance with suspension and debarment requirements. CARITAS will search for individuals listed on the government site on a quarterly basis and will retain notes on the
search in a folder to document the review.