Finding Text
Federal Agency: United States Department of Health and Human Services
Federal Program Name: Family Violence Prevention and Services
Assistance Listing Number: 93.592
Award Period: 9/30/2022-9/29/2023
Type of Finding:
• Significant Deficiency
Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6).
Condition: The Organization did not perform a SAMS.gov suspension & debarment check for their contracted hotel vendors.
Questioned costs: None.
Context: Two out of the five samples were deficient. However, CLA elected to a SAMS.gov check on 2/22/24 and noted that both hotels that were selected (Talking Stick Resort and Isleta Resort & Casino) were not debarred. These vendors were not checked as NIWRC was not aware that checks were required for hotels, even when hotels are subject to a contracted agreement (e.g., being used as a venue).
Cause: The Organization did not have a system in place to ensure the suspension & debarment compliance requirement was addressed for each applicable covered transactions.
Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.
Repeat Finding: No
Recommendation: CLA recommends the Organization increase training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed on all covered transactions.
Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.