Audit 321050

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

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