Audit 390523

Federal Agency: U.S. Dept. of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Office for Coastal Management Assistance Listing Number: 11.473 Federal Award Identification Year: 2025 Pass-Through Agency: California State Coastal Conservancy Award Period: 7/1/24-6/30/25 Compliance Requirement Affected: Suspension & Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.403(a) - When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: For five procured vendors that were selected for testing, documentation evidencing timely verification that each procured vendor was neither suspended or debarred was not retained. Context: A nonstatistical sample of five out of seven procured vendors were selected for testing for the above program. The condition noted above was identified during our procedures over the procured vendors. Effect: ESF did not retain documentation evidencing that suspension or debarment status of procured vendors was verified timely, which could result in procuring services with a suspended or debarred vendor. Cause: ESF did not consistently retain documentation evidencing procured vendors were verified for Suspension or Debarment status before procuring the vendor. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that ESF strengthen its current policies and procedures to ensure that evidence is retained showing Suspension and Debarment Status is verified for each vendor subject to verification of suspension and debarment verification according to ESF’s Procurement policy. Management’s Views: See separate corrective action plan.