ARC MASSACHUSETTS INC.Non-Profit

Name of Federal Agency: U.S. Department of Health and Human Services, Federal Program Name: Congressional Directives Assistance Listing Number: 93.493 Federal Award Identification Number and Year: Award number 90CFOD0036-01-00. Program Year 2025 Condition/Context For one procurement samples out of a total of one tested, management did not provide adequate supporting documentation for the procurement including proper suspension and debarment checks were performed before entering into a covered transaction with a vendor. Criteria In accordance with CFR 200.318(a), General Procurement Standards, a non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, CFR 200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. In addition, in accordance with 2 CFR 200.212 and 200.318(h); 2 CFR 180.300; 48 CFR 52.209-6, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities Cause The Organization did not have adequate policies, procedures and controls in place to ensure compliance with the general procurement standards and suspension and debarment requirements. Effect or Potential Effect Failure to timely verify that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred from performing work for the U.S. government. Identification as a Repeat Finding: This is not a repeat finding. Recommendation We recommend that the Agency enhance its written procurement policies and procedures to ensure that the Organization is in compliance with the Uniform Guidance and that the Organization maintains support which documents the suspension and debarment verification prior to entering into a covered transaction. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and completed the suspension and debarment review prior to entering into the covered transaction with the vendor however management did not maintain documentation. In addition, management subsequently confirmed with the contractor that the contractor was not suspended or debarred. Management is also in the process of enhancing its internal controls over procurement, suspension and debarment.