Stoddard County Public Health Center

Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323). Criteria: When a sub-recipient of federal awards uses federal money to acquire goods and services expected to cost more than $25,000, the sub-recipient must determine if the vendor is suspended, debarred, or otherwise excluded from doing business with the federal government. Condition: The Center purchased goods from one vendor totaling greater than $25,000 that required the Center to determine the vendor's status with the federal governmnet. The vendor was, in fact, not an excluded party. The Center needs to strengthen their internal control in place to ensure all vendors are verified before the disbursements are made. Cause: Management Oversight. Effect: Even though the Center did comply with the requirements not to purchase goods with excluded parties, failing to check the excluded parties list increases the risk that the Center will make payments to ineligible vendors and potentially claim inappropriate reimbursement. Questioned Costs: None. Context: Payments to an eligible vendor of the ELC program totaled $61,790. Repeat Finding: Yes. Recommendation: We recommend the Center verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and paid with federal grants. Views of Responsible Officials: We learned about this requirement during the prior year audit. However, the payment cited in this finding had already been made. Going forward we will verify all vendors' status using the System for Award Management (SAM) maintained by the General Services Administration b efore making purchases expected to exceed $25,000.

Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323). Criteria: When a sub-recipient of federal awards uses federal money to acquire goods and services expected to cost more than $25,000, the sub-recipient must determine if the vendor is suspended, debarred, or otherwise excluded from doing business with the federal government. Condition: The Center purchased goods from one vendor totaling greater than $25,000 that required the Center to determine the vendor's status with the federal government. the vendor was, in fact, not an excluded party. The center needs to strengthen their internal control in place to ensure all vendors are verified before the disbursements are made. Cause: Management oversight. Effect: Even though the Center did comply with the requirements not to purchase goods with excluded parties, failing to check the excluded parties list increases the risk that the Center will make payments to ineligible vendors and potentially claim inappropriate reimbursement. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend the Center verify a vendor's status by checking the Systemf or Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and paid with federal grants. Views of Responsible Officials: TheCenter will verify all vendors' status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000.

Federal Program: Family Planning Services (93.217). U.S. Department of the Health and Human Services passed through the Missouri Family Health Council, Inc. Criteria: According to 45 CFR 75.352 the pass-through entity is required to monitor activities of the subrecipient to ensure the subaward is used in compliance with federal statutes and regulations. Monitoring must include reviewing financial and performance reports required by the pass-through entity and ensuring that the subrecipient takes timely and appropriate action on all deficiencies detected through audits. Condition: The Center provided $194,588 of funding to five subrecipients. The Center did not provide any oversight monitoring of these other health center?s use of the grant funds. Cause: The Center relied on each subrecipient to be responsible and comply with the requirements of the grant. Effect: Lack of monitoring increases the risk that the subrecipients could not comply with a compliance requirement of the grant and it not be detected in a timely manner. Questioned Costs: None. Context: Total federal grant expenditures of the program were $328,581 during the year ended December 31, 2020. Repeat Finding: No. Recommendation: We recommend the Center require each subrecipient to submit monthly financial reports as well as reports of clients served. In addition, if any subrecipient is required to have an audit in accordance with Uniform Guidance, the Center should obtain a copy of the audit and follow up on any potential program related findings. Views of Responsible Officials and Planned Corrective Actions: The Center has already contacted the subrecipients to begin providing the required information on a monthly basis. The Center will begin providing the required oversight.

Federal Program: Family Planning Services (93.217). U.S. Department of the Health and Human Services passed through the Missouri Family Health Council, Inc. Criteria: Uniform Guidance requires policies related to cash management, cost allowability, procurement, and conflict of interest provisions, along with appropriate financial management systems and internal controls over federal awards to safeguard federal funds. Condition: The Center did not have written policies and procedures over the components of grant administration. Cause: The Center had no written policies and relied on each department head receiving grant funding to comply with all applicable compliance requirements. Effect: The federal government believes that not having written policies and procedures for grant administration increases the risk that the Center will not comply with applicable compliance requirements. Questioned Costs: None. Context: Total federal grant expenditures totaled $753,753 during the year ended December 31, 2020. Repeat Finding: No. Recommendation: We recommend the Center develop written policies and procedures related to cash management, cost allowability, procurement, and conflict of interest provisions for federal funds it receives. Views of Responsible Officials and Planned Corrective Actions: The Center has already developed and adopted the appropriate written policies in order to implement this recommendation.