Finding No.: 2023-001
Federal Agency: U.S. Department of Education
AL Program: 84.425L COVID-19 – Higher Education Emergency Relief Fund Minority
Serving Institutions
Federal Award No.: P425L200532
Area: Allowable Costs/Cost Principles – Indirect Costs
Questioned Costs: $0
Criteria:
In accordance with the University’s federal negotiated indirect cost rate agreement applicable for
the fiscal year ended September 30, 2023, modified total direct costs to be used as the base for
calculating indirect costs shall exclude equipment, capital expenditures, charges for patient care,
rental costs, tuition remission, scholarships and fellowships, participant support costs, and the
portion of each subaward in excess of $25,000.
Condition:
In our testing of total indirect costs during the fiscal year ended September 30, 2023, we noted that
unallowable cost bases were used in the calculation of indirect costs. Details follow:
Base Base Amount Indirect Cost Rate Indirect Cost Amount
Capital expenditures $ 87,686 39% $ 34,198
Lost revenues 180,421 39% 70,364
Total indirect cost unallowed $104,562
The University subsequently recharacterized these indirect costs to lost revenues.
Cause:
The University used inappropriate cost bases in calculating indirect costs charged to the program.
Effect:
The University is in noncompliance with the applicable requirement. However, no questioned
costs is reported as the costs were subsequently recharacterized from indirect costs to lost revenues.
Recommendation:
The University should ensure that calculations of indirect costs to be applied to Federal programs
are made using allowed cost bases identified in the indirect cost rate agreement or applicable grant
award.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-001
Federal Agency: U.S. Department of Education
AL Program: 84.425L COVID-19 – Higher Education Emergency Relief Fund Minority
Serving Institutions
Federal Award No.: P425L200532
Area: Allowable Costs/Cost Principles – Indirect Costs
Questioned Costs: $0
Criteria:
In accordance with the University’s federal negotiated indirect cost rate agreement applicable for
the fiscal year ended September 30, 2023, modified total direct costs to be used as the base for
calculating indirect costs shall exclude equipment, capital expenditures, charges for patient care,
rental costs, tuition remission, scholarships and fellowships, participant support costs, and the
portion of each subaward in excess of $25,000.
Condition:
In our testing of total indirect costs during the fiscal year ended September 30, 2023, we noted that
unallowable cost bases were used in the calculation of indirect costs. Details follow:
Base Base Amount Indirect Cost Rate Indirect Cost Amount
Capital expenditures $ 87,686 39% $ 34,198
Lost revenues 180,421 39% 70,364
Total indirect cost unallowed $104,562
The University subsequently recharacterized these indirect costs to lost revenues.
Cause:
The University used inappropriate cost bases in calculating indirect costs charged to the program.
Effect:
The University is in noncompliance with the applicable requirement. However, no questioned
costs is reported as the costs were subsequently recharacterized from indirect costs to lost revenues.
Recommendation:
The University should ensure that calculations of indirect costs to be applied to Federal programs
are made using allowed cost bases identified in the indirect cost rate agreement or applicable grant
award.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-001
Federal Agency: U.S. Department of Education
AL Program: 84.425L COVID-19 – Higher Education Emergency Relief Fund Minority
Serving Institutions
Federal Award No.: P425L200532
Area: Allowable Costs/Cost Principles – Indirect Costs
Questioned Costs: $0
Criteria:
In accordance with the University’s federal negotiated indirect cost rate agreement applicable for
the fiscal year ended September 30, 2023, modified total direct costs to be used as the base for
calculating indirect costs shall exclude equipment, capital expenditures, charges for patient care,
rental costs, tuition remission, scholarships and fellowships, participant support costs, and the
portion of each subaward in excess of $25,000.
Condition:
In our testing of total indirect costs during the fiscal year ended September 30, 2023, we noted that
unallowable cost bases were used in the calculation of indirect costs. Details follow:
Base Base Amount Indirect Cost Rate Indirect Cost Amount
Capital expenditures $ 87,686 39% $ 34,198
Lost revenues 180,421 39% 70,364
Total indirect cost unallowed $104,562
The University subsequently recharacterized these indirect costs to lost revenues.
Cause:
The University used inappropriate cost bases in calculating indirect costs charged to the program.
Effect:
The University is in noncompliance with the applicable requirement. However, no questioned
costs is reported as the costs were subsequently recharacterized from indirect costs to lost revenues.
Recommendation:
The University should ensure that calculations of indirect costs to be applied to Federal programs
are made using allowed cost bases identified in the indirect cost rate agreement or applicable grant
award.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-001
Federal Agency: U.S. Department of Education
AL Program: 84.425L COVID-19 – Higher Education Emergency Relief Fund Minority
Serving Institutions
Federal Award No.: P425L200532
Area: Allowable Costs/Cost Principles – Indirect Costs
Questioned Costs: $0
Criteria:
In accordance with the University’s federal negotiated indirect cost rate agreement applicable for
the fiscal year ended September 30, 2023, modified total direct costs to be used as the base for
calculating indirect costs shall exclude equipment, capital expenditures, charges for patient care,
rental costs, tuition remission, scholarships and fellowships, participant support costs, and the
portion of each subaward in excess of $25,000.
Condition:
In our testing of total indirect costs during the fiscal year ended September 30, 2023, we noted that
unallowable cost bases were used in the calculation of indirect costs. Details follow:
Base Base Amount Indirect Cost Rate Indirect Cost Amount
Capital expenditures $ 87,686 39% $ 34,198
Lost revenues 180,421 39% 70,364
Total indirect cost unallowed $104,562
The University subsequently recharacterized these indirect costs to lost revenues.
Cause:
The University used inappropriate cost bases in calculating indirect costs charged to the program.
Effect:
The University is in noncompliance with the applicable requirement. However, no questioned
costs is reported as the costs were subsequently recharacterized from indirect costs to lost revenues.
Recommendation:
The University should ensure that calculations of indirect costs to be applied to Federal programs
are made using allowed cost bases identified in the indirect cost rate agreement or applicable grant
award.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-001
Federal Agency: U.S. Department of Education
AL Program: 84.425L COVID-19 – Higher Education Emergency Relief Fund Minority
Serving Institutions
Federal Award No.: P425L200532
Area: Allowable Costs/Cost Principles – Indirect Costs
Questioned Costs: $0
Criteria:
In accordance with the University’s federal negotiated indirect cost rate agreement applicable for
the fiscal year ended September 30, 2023, modified total direct costs to be used as the base for
calculating indirect costs shall exclude equipment, capital expenditures, charges for patient care,
rental costs, tuition remission, scholarships and fellowships, participant support costs, and the
portion of each subaward in excess of $25,000.
Condition:
In our testing of total indirect costs during the fiscal year ended September 30, 2023, we noted that
unallowable cost bases were used in the calculation of indirect costs. Details follow:
Base Base Amount Indirect Cost Rate Indirect Cost Amount
Capital expenditures $ 87,686 39% $ 34,198
Lost revenues 180,421 39% 70,364
Total indirect cost unallowed $104,562
The University subsequently recharacterized these indirect costs to lost revenues.
Cause:
The University used inappropriate cost bases in calculating indirect costs charged to the program.
Effect:
The University is in noncompliance with the applicable requirement. However, no questioned
costs is reported as the costs were subsequently recharacterized from indirect costs to lost revenues.
Recommendation:
The University should ensure that calculations of indirect costs to be applied to Federal programs
are made using allowed cost bases identified in the indirect cost rate agreement or applicable grant
award.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-001
Federal Agency: U.S. Department of Education
AL Program: 84.425L COVID-19 – Higher Education Emergency Relief Fund Minority
Serving Institutions
Federal Award No.: P425L200532
Area: Allowable Costs/Cost Principles – Indirect Costs
Questioned Costs: $0
Criteria:
In accordance with the University’s federal negotiated indirect cost rate agreement applicable for
the fiscal year ended September 30, 2023, modified total direct costs to be used as the base for
calculating indirect costs shall exclude equipment, capital expenditures, charges for patient care,
rental costs, tuition remission, scholarships and fellowships, participant support costs, and the
portion of each subaward in excess of $25,000.
Condition:
In our testing of total indirect costs during the fiscal year ended September 30, 2023, we noted that
unallowable cost bases were used in the calculation of indirect costs. Details follow:
Base Base Amount Indirect Cost Rate Indirect Cost Amount
Capital expenditures $ 87,686 39% $ 34,198
Lost revenues 180,421 39% 70,364
Total indirect cost unallowed $104,562
The University subsequently recharacterized these indirect costs to lost revenues.
Cause:
The University used inappropriate cost bases in calculating indirect costs charged to the program.
Effect:
The University is in noncompliance with the applicable requirement. However, no questioned
costs is reported as the costs were subsequently recharacterized from indirect costs to lost revenues.
Recommendation:
The University should ensure that calculations of indirect costs to be applied to Federal programs
are made using allowed cost bases identified in the indirect cost rate agreement or applicable grant
award.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.
Finding No.: 2023-002
Federal Agency: Various
AL Program: COVID-19 – 84.425 Education Stabilization Fund
R&D Cluster
Federal Award No.: Various
Area: Suspension and Debarment
Questioned Costs: $0
Criteria:
In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR
180.300, when entering into a covered transaction with another person at the next lower tier,
verification must be made that the person with whom an intent to do business with is not excluded
or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a
certification from that person; or (c) adding a clause or condition to the covered transaction with
that person.
Condition:
The University represented that it performs regular verification from SAM Exclusions, however,
no formal documentation is kept on procurement files as evidence of procedures performed.
Cause:
The University did not properly document that verification was performed to identify if the
selected person or entity in the covered transaction was not suspended or debarred prior to
transacting with them.
Effect:
The University is in noncompliance with the applicable requirement.
Recommendation:
The University should revisit and implement its procedures to ensure that vendors and entities that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities are restricted from Federal awards, subawards and contracts.
Procedures performed should be adequately maintained in the procurement files.
Views of Responsible Officials:
See Corrective Action Plan.