Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.
Finding 2023-001: Suspension and Debarment
Information on Federal Program: 47.074
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific
requirements on screening of all potential and current vendors, suppliers, contractors,
subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties
(as defined by the United States Government). This screening process must also be documented
in writing.
Condition: The Society did not consistently perform the screening process for its potential and
current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. The issue is deemed to be
systemic.
Cause: The Society did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, and subrecipients.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None
Identification of Repeat Finding: N/A
Recommendation: We recommend that the Society establish policies and ensure that all types of
parties (as noted above) are included, and educate its employees on the procedures necessary to
ensure full compliance with this requirement. We also recommend that the Society document each
of these screenings and retain them in the respective files, which should be completed prior to
engaging in relationships with these parties. For ongoing relationships, the Society should consider
performing screenings on an annual basis (and documenting them) to ensure continuous
compliance in the event the suspension and debarment status of any of these parties changes.
Lastly, we recommend the Society perform retrospective screenings on these parties to which it
made payments during the fiscal year.