SWINE HEALTH INFORMATION CENTER, INC.Non-Profit

2020 ? 003: Suspension and Debarment Federal agency: U.S. Department of Agriculture Federal program: Section 108 Foreign Currency Program CFDA Number: 10.617 Award Period: 9/1/2019 ? 8/31/2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Per Uniform Guidance ?200.214 Suspension and Debarment, the Organization is subject to debarment and suspension regulations, which 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. Condition: We noted there was no documentation to support a search was performed on a vendor prior to entering into a contract for services to ensure the vendor was not suspended or debarred. Questioned costs: None Context: For two out of two vendor contracts tested, we noted there was no documentation supporting a review to ensure the vendor was not suspended or debarred. Cause: The Organization has not implemented formal policies and procedures to ensure proper procedures are being followed as it relates to suspension and debarment. Effect: Without the proper procedure in place, the Organization may enter into a contract with a vendor who has been suspended or debarred resulting in unallowable costs being incurred. Repeat Finding: No Recommendation: We recommend the Organization implement a formal procurement policy that includes procedures for suspension and debarment. Views of responsible officials and planned corrective actions: There is no disagreement with the finding.

2020 ? 004: Subrecipient Monitoring Federal agency: U.S. Department of Agriculture Federal program: Section 108 Foreign Currency Program CFDA Number: 10.617 Award Period: 9/1/2019 ? 8/31/2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Per Uniform Guidance ?200.332, Requirements for Pass-through Entities, the Organization should ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required information. Condition: We noted the following information to be missing from the subaward agreements: ? Federal award identification, including the subrecipients unique entity identifier, Federal Award Identification Number (FAIN), federal award date, federal project description, as required to be responsive to the Federal Funding Accountability Transparency Act, name of the federal awarding agency, CFDA and title of the federal award, and indirect cost rate of the award. ? All requirements imposed by the Organization on the subrecipient so that the federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award. Questioned costs: None Context: We noted there is no formal policy in place for monitoring subrecipients or process in place to ensure subawards contain the required information to comply with federal funding requirements. Cause: The Organization has not implemented formal policies and procedures to ensure proper procedures are being followed as it relates to subrecipient monitoring and awards. Effect: Without the proper procedure in place, the Organization may enter into a contract with a vendor who is not aware the funding is coming from federal funds, thus resulting in unallowable costs being incurred. Repeat Finding: No Recommendation: We recommend the Organization review CFR 200 so as to be familiar with federal funding requirements and to implement a formal policy that includes procedures ensuring all required communications are included in subawards. Views of responsible officials and planned corrective actions: There is no disagreement with the finding.