Infectious Diseases Society of America

Federal agency: Center for Disease Control and Prevention Federal program title: Protecting and Improving Health Globally Assistance Listing Number: 93.318 Award Period: 09/30/2021-09/29/2024 • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. 2 CFR Part 180.220, states that recipients of federal funds are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by: (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity IDSA should have internal controls designed and effectively operating to ensure compliance with those provisions. Condition: During our testing, we noted IDSA did not maintain support to show its review of the search for suspension and debarment was done before contracts were entered into. IDSA did not have effective controls to ensure vendors were not suspended or debarred. Questioned costs: None Context: For one out of one vendor tested, we noted that documentation related to suspension and debarment verification was dated after the contract was entered into. However, our testing did not identify any vendors that had been suspended or debarred. Cause: The policies and procedures surrounding suspension and debarment verification were not consistently followed as designed. Effect: CLA noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of effective internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend IDSA ensure consistent application of its policies and procedures so that an adequate verification process is in place to review potential contractors to determine they are not suspended or debarred before entering into the contract. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.

Protecting and Improving Health Globally – Assistance Listing No. 93.318 Recommendation: We recommend IDSA ensure consistent application of its policies and procedures so that an adequate verification process is in place to review potential contractors to determine they are suspended or debarred before entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our internal procedures call for a verification check for suspension or debarment for every new vendor, and a check of all vendors at the beginning of each budget year. Unfortunately, for the new budget year that began on September 30, 2023, we did not perform this check for one of our long time vendors, University of Iowa. Although the audit finding is accurate, there is minimal exposure for suspension or debarment for this vendor, since the university is part of the State of Iowa. Name of the contact person responsible for corrective action: Barton Groh, Vice President of Finance & Administration Planned completion date for corrective action plan: We will insure that we follow our procedures and perform this check for all vendors, including the University of Iowa, before the start of our new budget period on September 30, 2024. We will also follow our procedures and perform this check for any new vendors that we use in the new budget year. If the Department of Health and Human Services has questions regarding this plan, please call Barton Groh, Vice President of Finance & Administration at 703-299-0108.

2021-002 Suspension and Debarment Federal agency: Center for Disease Control and Prevention Federal program title: Protecting and Improving Health Globally Assistance Listing Number: 93.318 Award Period: 12/01/2020 ? 09/29/2025 ? Significant Deficiency in Internal Control over Compliance During our testing, we noted IDSA did not maintain support to show its review of the search for suspension and debarment was done before contracts were entered into. IDSA did not have effective controls to ensure vendors were not suspended or debarred. The five vendors that were identified as deficient for timely testing for suspension and debarment were all entered into before the release of the 2020 Schedule of Findings and Questioned Costs, when the deficiency was first reported. We did not identify any suspension and debarment exceptions for contracts that were entered into after the previous year report date.

Recommendation: We recommend IDSA ensure consistent application of its policies and procedures so that an adequate verification process is in place to review potential contractors to determine they are not suspended or debarred before entering into the contract. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding. Action taken in response to finding: We received this recommendation in June 2021 as part of the 2020 compliance audit. At that time, we implemented a procedure to perform all contractor verifications for suspension or debarment by checking the System for Award Management (SAM) prior to contract signing and start of work. The five vendors that were identified as deficient in the 2021 compliance audit for timely testing of the SAM system for suspension and debarment all entered into contracts with IDSA before the release of the 2020 Schedule of Findings and Questioned Costs, when the deficiency was first reported. The auditors did not identify any suspension and debarment exceptions for contracts that were entered into after the previous year report date. We believe that our procedures are working correctly, based on internal sampling of new contracts after June 2021, and based on auditor testing for 2021 compliance testing, and that no additional steps are required. Name of the contact person responsible for corrective action: Barton Groh, Vice President of Finance & Administration Planned completion date for corrective action plan: June 2021 (already completed)

2020-001

2020-001 Suspension and Debarment Federal agency: Center for Disease Control and Prevention Federal program title: Emerging Infections Sentinel Network CFDA Number: 93.860 Award Period: 7/1/19 ? 6/30/21 ? Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. 2 CFR Part 180.220, states that recipients of federal funds are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by: (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity IDSA should have internal controls designed and effectively operating to ensure compliance with those provisions. Condition: During our testing, we noted IDSA did not maintain support to show its review of the search for suspension and debarment was done before contracts were entered into. IDSA did not have effective controls to ensure vendors were not suspended or debarred. Questioned costs: None. Context: For five out of five vendors tested, we noted that documentation related to suspension and debarment verification was dated after the contract was entered into. However, our testing did not identify any vendors that had been suspended or debarred. Cause: The policies and procedures surrounding suspension and debarment verification were not consistently followed as designed. Effect: CLA noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of effective internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: N/A. Recommendation: We recommend IDSA ensure consistent application of its policies and procedures so that an adequate verification process is in place to review potential contractors to determine they are not suspended or debarred before entering into the contract. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.

Infectious Diseases Society of America and Affiliate respectfully submits the following corrective action plan for the year ended December 31, 2020. Action taken in response to finding: IDSA concurs with this recommendation. We began discussions with the Centers of Disease Control (CDC) in March 2020 to coordinate the assistance of our member infectious disease physicians in answering calls from clinicians to CDC?s call center. Those initial discussions later grew into a broader set of resources, developed in conjunction with CDC staff, to disseminate information to clinicians and the general public about the emerging COVID pandemic, which ultimately led to the award dated May 13, 2020. Due to the unprecedented nature of the pandemic and the speed with which it affected the world, we initially focused IDSA?s efforts on redirecting existing staff towards the objectives of the award, building a team of technical medical experts that could accomplish those objectives and ongoing direction from CDC staff, and building internal processes to accurately capture costs related to the award. As a result of the many critical priorities associated with this project and the tight timeframes under which we implemented the program, we did not take the required step of verifying that our contracted vendors had not been suspended or debarred until after those vendors had signed contracts and begun work. However, IDSA did verify, on a retrospective basis, that none of our vendors had active exclusion records in SAM.gov. Name(s) of the contact person(s) responsible for corrective action: Barton Groh Planned completion date for corrective action plan: In December 2020, IDSA provided mandatory training to all employees supporting our federal programs to review the organization?s procurement policy. Prior to July 1, 2021, IDSA will incorporate into our Procurement Process Instruction and train our employees on the requirement to verify the status of suspension or debarment for any new vendors prior to entering into a contract and beginning work, and will also maintain documentation of that review for any existing vendors. If the Centers for Disease Control and Prevention has questions regarding this plan, please call: Barton Groh, Vice President of Finance & Administration, 703-299-0108