EIN: 030445789
UEI: NKKANJSDRCB5
Audited by: CliftonLarsonAllen LLP
Oversight agency: 93 [Department of Health and Human Services]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 14, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by April 14, 2026 (143 days ago).
What is a management decision? →FAC accepted this audit on September 13, 2024 — management decision was due March 13, 2025.
During our testing, there was one vendor tested in our sample that was above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. Questioned costs: None Context: During out testing, noted no proper documentation per the procurement policy. Vendor was utilized due to past work performed for the Organization and experience the vendor had with other similar organizations, but documentation should still be maintained when sole source procurement is utilized. Cause: The Organization did not follow the policy due to working with the vendor in the past and time constraints, however, did not maintain documentation as to why sole source procurement was utilized. Effect: The lack of documented procurement policies over these compliance requirements provides an opportunity for noncompliance. Repeat finding: No Recommendation: We recommend the Organization utilize a noncompetitive procurement justification form if following standard procurement procedures is not feasible. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/23 – 12/31/23, 4/1/21 – 3/31/23, 12/1/22 – 12/31/23, and 9/1/23 – 12/31/24 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.320 states the non-Federal entity must have and use documented procurement procedures following specific requirements for different methods of procurement depending on size and type of purchase. Thresholds for these categories (micro-purchase, simplified acquisition threshold) refer to using the Federal Acquisition Regulations (FAR), unless a different threshold has been specifically approved. Specifically, under FAR multiple quotes are generally required for purchases over the micro-purchase threshold, or documentation should be maintained explaining why multiple quotes were not obtained. Condition: During our testing, there was one vendor tested in our sample that was above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. Questioned costs: None Context: During out testing, noted no proper documentation per the procurement policy. Vendor was utilized due to past work performed for the Organization and experience the vendor had with other similar organizations, but documentation should still be maintained when sole source procurement is utilized. Cause: The Organization did not follow the policy due to working with the vendor in the past and time constraints, however, did not maintain documentation as to why sole source procurement was utilized. Effect: The lack of documented procurement policies over these compliance requirements provides an opportunity for noncompliance. Repeat finding: No Recommendation: We recommend the Organization utilize a noncompetitive procurement justification form if following standard procurement procedures is not feasible. Views of responsible officials: There is no disagreement with the audit finding.
Health Centers Cluster – Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization utilize a noncompetitive procurement justification form if following standard procurement procedures is not feasible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will utilize a form to document noncompetitive procurement moving forward when applicable. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2024
FAC accepted this audit on August 27, 2023 — management decision was due February 27, 2024.
During our testing, we noted the Organization used its provisional federal IDCR for the whole period, but a final IDCR agreement was received in September 2022 reducing the IDCR for the whole grant period. Eligible expenses and drawdowns were not reconciled for change in IDCR after the change. Questioned costs: None Context: While the IDCR decreased during the year, the Organization had sufficient other eligible expenditures to make up for the difference in IDCR used compared to the final IDCR. The Organization just missed the process of reallocating expenses in the system to make up for the drop in indirect expenses. For the grant impacted, subsequent to year-end more eligible expenditures have already been identified than would be needed with the revised rated to utilize the full grant. Cause: While the Organization had a process in place to make sure the approved IDCR was setup in the system to calculate indirect costs at the start of the grant, there was not a process in place to revise that IDCR in the event the provisional rate was finalized. Effect: Without a process to properly update and reconcile indirect costs in the event of an IDCR change, the Organization risks overstating total eligible expenditures and noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200 states the non-Federal entity may utilize a federally agreed upon indirect cost rate (IDCR) in identifying eligible expenditures under a federal grant. A provisional IDCR may be issued, but billing reconciliation should be done when a final IDCR agreement is issued. Condition: During our testing, we noted the Organization used its provisional federal IDCR for the whole period, but a final IDCR agreement was received in September 2022 reducing the IDCR for the whole grant period. Eligible expenses and drawdowns were not reconciled for change in IDCR after the change. Questioned costs: None Context: While the IDCR decreased during the year, the Organization had sufficient other eligible expenditures to make up for the difference in IDCR used compared to the final IDCR. The Organization just missed the process of reallocating expenses in the system to make up for the drop in indirect expenses. For the grant impacted, subsequent to year-end more eligible expenditures have already been identified than would be needed with the revised rated to utilize the full grant. Cause: While the Organization had a process in place to make sure the approved IDCR was setup in the system to calculate indirect costs at the start of the grant, there was not a process in place to revise that IDCR in the event the provisional rate was finalized. Effect: Without a process to properly update and reconcile indirect costs in the event of an IDCR change, the Organization risks overstating total eligible expenditures and noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Health and Human Services 2022-002 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement processes to review the IDCR used to ensure any changes are incorporated timely and reconciled, as needed. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2023
During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/22 ? 12/31/22, 4/1/21 ? 3/31/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did follow formal policies and procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract, however for one of two selections tested the incorrect vendor name was used. Therefore, the internal control did not function as designed and the actual vendor used did not have documentation retained around check for exclusions. Questioned costs: None Context: During our testing, a sample of two disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization followed procedures in both cases to check vendors against the 'System for Award Management (SAM) Exclusions'. For one of the vendors, however, the incorrect vendor name was used, and therefore incorrect data retained to support the exclusion check. In addition, the incorrect vendor did have a federal exclusion. The vendor the Organization actually used did not have an exclusion. Cause: The finding is just the result of manual error as an acronym was used for the vendor in the search that resulted in a different, incorrect vendor being the search result. Effect: If suspension and debarment policies and procedures are not operating effectively, it provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: No Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Health and Human Services 2022-003 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will follow suspension and disbarment policy and incorporate procedures to ensure correct vendor is researched via identification methods outside of just vendor name. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2023
2021-003
FAC accepted this audit on September 12, 2022 — management decision was due March 12, 2023.
During our testing, we noted the Organization did not have properly documented procurement policy that met the federal requirements until 10/1/21. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. Questioned costs: None Context: During our testing, it was noted that the Organization had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all the necessary elements, as required by federal regulations until 10/1/21. Also noted none of the 10 procurements selected had sufficient documentation per the policies to support the method of procurement. Cause: The Organization had not yet updated their procurement policy to meet Uniform Guidance requirements until 10/1/21. After that, sufficient documentation was not retained to support the procedures being completed under the new policy. Effect: The lack of documented procurement policies over these compliance requirements provides an opportunity for noncompliance. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2020-004. Recommendation: We recommend the Organization follow the newly implemented procurement policy, and ensure proper documentation is retained for transactions, particularly in cases where single source or noncompetitive procurement is utilized over the micro-purchase threshold. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23, 9/15/21 ? 9/14/24 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.320 states the non-Federal entity must have and use documented procurement procedures following specific requirements for different methods of procurement depending on size and type of purchase. Thresholds for these categories (micro-purchase, simplified acquisition threshold) refer to using the Federal Acquisition Regulations (FAR), unless a different threshold has been specifically approved. Specifically, under FAR multiple quotes are generally required for purchases over the micro-purchase threshold, or documentation should be maintained explaining why multiple quotes were not obtained. Condition: During our testing, we noted the Organization did not have properly documented procurement policy that met the federal requirements until 10/1/21. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available or appropriate to support why noncompetitive procurement was followed. Questioned costs: None Context: During our testing, it was noted that the Organization had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all the necessary elements, as required by federal regulations until 10/1/21. Also noted none of the 10 procurements selected had sufficient documentation per the policies to support the method of procurement. Cause: The Organization had not yet updated their procurement policy to meet Uniform Guidance requirements until 10/1/21. After that, sufficient documentation was not retained to support the procedures being completed under the new policy. Effect: The lack of documented procurement policies over these compliance requirements provides an opportunity for noncompliance. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2020-004. Recommendation: We recommend the Organization follow the newly implemented procurement policy, and ensure proper documentation is retained for transactions, particularly in cases where single source or noncompetitive procurement is utilized over the micro-purchase threshold. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Health and Human Services 2021-002 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization follow the newly implemented procurement policy, and ensure proper documentation is retained for transactions, particularly in cases where single source or noncompetitive procurement is utilized over the micro-purchase threshold. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement the newly created policy and ensure sufficient documentation is retained to support procurement determinations. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2022
2020-004
During our testing, we noted the Organization did not follow formal policies or procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of five disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization did not have a process to check the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred, or retain related support. All five vendors selected were compared to the SAM Exclusions at the time of testing, and none were noted to be suspended or disbarred, although the testing could not be performed back to the date of the transactions. Cause: The Organization did not have a formal suspension and disbarment policy in place that meets Uniform Guidance requirements. After 10/1/21, a policy was in place but not followed. Effect: The lack of a formal suspension and debarment policy, or not following a policy in place, provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2020-005. Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and retain appropriate documentation to support the procedures being performed. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 003 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster Assistance Listing Number: 93.224/93.527 Award Period: Varying project and budget periods: 1/1/21 ? 12/31/21, 4/1/20 ? 3/31/21, 5/1/20 ? 4/30/21, 3/15/20 ? 3/14/21, 4/1/21 ? 3/31/23, 9/15/21 ? 9/14/24 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did not follow formal policies or procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of five disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization did not have a process to check the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred, or retain related support. All five vendors selected were compared to the SAM Exclusions at the time of testing, and none were noted to be suspended or disbarred, although the testing could not be performed back to the date of the transactions. Cause: The Organization did not have a formal suspension and disbarment policy in place that meets Uniform Guidance requirements. After 10/1/21, a policy was in place but not followed. Effect: The lack of a formal suspension and debarment policy, or not following a policy in place, provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2020-005. Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and retain appropriate documentation to support the procedures being performed. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Health and Human Services 2021-003 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and retain appropriate documentation to support the procedures being performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement suspension and disbarment procedures to follow the newly developed procurement policy and retain sufficient information to support procedures being performed. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2022
2020-005
FAC accepted this audit on October 31, 2021 — management decision was due May 1, 2022.
During our testing, we noted the Organization did not have properly documented procurement policy that met the federal requirements. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available to support why noncompetitive procurement was followed. Questioned costs: None Context: During our testing, it was noted that the Organization had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all of the necessary elements, as required by federal regulations. Specifically, purchases under $25,000, but above the micro-purchase threshold, do not require multiple price quotes. Due to the Organization?s policy, the internal micro-purchase threshold is set at $1,000, so there were 13 of 15 transactions tested between $1,000 and $25,000 where there was not documentation or support for multiple price quotes, or documentation on why sole source procurement was followed. Cause: The Organization had not yet updated their procurement policy to meet Uniform Guidance requirements. Effect: The lack of documented procurement policies over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization create and implement a procurement policy that meets the requirements of federal regulations. The Organization could consider raising thresholds for micro purchase and simplified acquisition threshold to the maximums allowed under Uniform Guidance to reduce administrative burden, although more restrictive policies are allowed if desired by the Organization. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 004 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster & Substance Abuse and Mental Health Services Projects of Regional and National Significance CFDA Number: 93.224/93.527 & 93.243 Award Period: 93.224/93.527 ? 1/1/20 ? 12/31/20, 93.243 ? 9/30/18 ? 9/29/21 & 8/31/20 ? 8/30/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.320 states the non-Federal entity must have and use documented procurement procedures following specific requirements for different methods of procurement depending on size and type of purchase. Thresholds for these categories (micro-purchase, simplified acquisition threshold) refer to using the Federal Acquisition Regulations (FAR), unless a different threshold has been specifically approved. Specifically, under FAR multiple quotes are generally required for purchases over the micro-purchase threshold, or documentation should be maintained explaining why multiple quotes were not obtained. Condition: During our testing, we noted the Organization did not have properly documented procurement policy that met the federal requirements. In addition, there were specific transactions tested in our sample that were above the micro-purchase threshold, but multiple quotes were not obtained, and documentation was not available to support why noncompetitive procurement was followed. Questioned costs: None Context: During our testing, it was noted that the Organization had documented procurement procedures, which described individuals and parties responsible throughout the procurement process; however, it did not contain all of the necessary elements, as required by federal regulations. Specifically, purchases under $25,000, but above the micro-purchase threshold, do not require multiple price quotes. Due to the Organization?s policy, the internal micro-purchase threshold is set at $1,000, so there were 13 of 15 transactions tested between $1,000 and $25,000 where there was not documentation or support for multiple price quotes, or documentation on why sole source procurement was followed. Cause: The Organization had not yet updated their procurement policy to meet Uniform Guidance requirements. Effect: The lack of documented procurement policies over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization create and implement a procurement policy that meets the requirements of federal regulations. The Organization could consider raising thresholds for micro purchase and simplified acquisition threshold to the maximums allowed under Uniform Guidance to reduce administrative burden, although more restrictive policies are allowed if desired by the Organization. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Health and Human Services 2020-004 Health Centers Cluster & Substance Abuse and Mental Health Services Projects of Regional and National Significance ? Assistance Listing No. 93.224/93.527 & 93.243 Recommendation: We recommend the Organization create and implement a procurement policy that meets the requirements of federal regulations. The Organization could consider raising thresholds for micro purchase and simplified acquisition threshold to the maximums allowed under Uniform Guidance to reduce administrative burden, although more restrictive policies are allowed if desired by the Organization. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will revise procurement policy to meet Uniform Guidance requirements, and ensure procedures are revised to follow the updated policy. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2021
During our testing, we noted the Organization did not have formal policies or procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of seven disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization did not have a process to check the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred, or retain related support. All seven vendors selected were compared to the SAM Exclusions at the time of testing, and none were noted to be suspended or disbarred, although the testing could not be performed back to the date of the transactions. Cause: The Organization does not have a formal suspension and disbarment policy in place that meets Uniform Guidance requirements. Effect: The lack of a formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat Finding: No Recommendation: We recommend the Organization create and implement a suspension and disbarment policy that meets the requirements of federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 005 Federal agency: U.S. Department of Health and Human Services Federal program title: Health Centers Cluster & Substance Abuse and Mental Health Services Projects of Regional and National Significance CFDA Number: 93.224/93.527 & 93.243 Award Period: 93.224/93.527 ? 1/1/20 ? 12/31/20, 93.243 ? 9/30/18 ? 9/29/21 & 8/31/20 ? 8/30/23 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations section 200.214 requires the Organization to follow the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The Organization should have policies and procedures in place to ensure contracts or subaward are not provided to third parties that are suspended or disbarred. Condition: During our testing, we noted the Organization did not have formal policies or procedures in place to determine if vendors have been suspended or disbarred prior to entering into a contract. Questioned costs: None Context: During our testing, a sample of seven disbursement transactions greater than $25,000 were selected for suspension and disbarment testing. The Organization did not have a process to check the 'System for Award Management (SAM) Exclusions' or other procedures to ensure third parties were not suspended or disbarred, or retain related support. All seven vendors selected were compared to the SAM Exclusions at the time of testing, and none were noted to be suspended or disbarred, although the testing could not be performed back to the date of the transactions. Cause: The Organization does not have a formal suspension and disbarment policy in place that meets Uniform Guidance requirements. Effect: The lack of a formal suspension and debarment policy provides the opportunity for noncompliance due to transactions with suspended or disbarred parties. Repeat Finding: No Recommendation: We recommend the Organization create and implement a suspension and disbarment policy that meets the requirements of federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Health and Human Services 2020-005 Health Centers Cluster & Substance Abuse and Mental Health Services Projects of Regional and National Significance ? Assistance Listing No. 93.224/93.527 & 93.243 Recommendation: We recommend the Organization create and implement a suspension and disbarment policy that meets the requirements of federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will develop and implement a suspension and disbarment policy to meet Uniform Guidance requirements, and ensure procedures are revised to follow the updated policy. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2021
FAC accepted this audit on June 25, 2020 — management decision was due December 25, 2020.
FAC accepted this audit on August 20, 2019 — management decision was due February 20, 2020.
FAC accepted this audit on September 27, 2018 — management decision was due March 27, 2019.
FAC accepted this audit on July 17, 2017 — management decision was due January 17, 2018.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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