Audit 373406

Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include 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 as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: Internal controls did not include verifiable check on www.sam.gov for an entity’s suspension or debarment status prior to entering into the covered transactions. EDB does not have documented S&D policies nor a documented procedure for checking for suspension and debarment. Questioned costs: None Context: In a statistically valid sample, CLA tested five of seven covered transactions that should have been subject to suspension and debarment checks. Testing determined that no documentation was kept to substantiate that S&D checks were performed, but upon review of the subrecipients/vendors on SAM.gov, CLA determined that none of the tested subrecipients/vendors were federally suspended nor debarred. Cause: Due to lack of policy in place for suspension and debarment that does not include documentation of vendor check for suspension and debarment. However, CLA was able to verify selected vendors were not suspended or debarred via SAM.gov check. Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred. Repeat Finding: No Recommendation: CLA recommends EDB update policies to match Uniform Guidance requirements and to update procedures to require document be kept showing that suspension and debarment checks are done prior to entering into a covered transaction.