Audit 380893

Finding 2025-001 Program Affected AL 21.027 Coronavirus State and Local Fiscal Recovery Funds – Agreement period September 15, 2022 through June 30, 2026 Criteria 2 CFR 180.300 details the requirement when, “entering a covered transaction with another person at the next lower tier, they must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person.” Condition and Context In consideration of procurement, and suspension and debarment under this program, the University did not have auditable evidence of testing vendors with the requirements of 2 CFR 180.300 for verifying a vendor is not excluded or disqualified from doing business with an entity that receives federal funds. We selected three vendors and five employees to compare to the exclusion system and did not identify any excluded parties in our testing. Questioned Costs None noted. Cause and Effect The University currently lacks a formal process to review vendors against the System for Award Management (SAM) exclusion list, collecting a formal certification from the vendor or adding a clause to the covered transaction with the vendor. Without a formal policy addressing the process of suspension and debarment check, there is risk of working with a suspended or debarred entity resulting in noncompliant use of federal funds. Recommendation We recommend implementing a formal process when entering arrangements with external parties to check they are not suspended or debarred on the SAM Exclusions list. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding. See attached Corrective Action Plan.