Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires that when a non-federal entity plans to enter 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. 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 (2 CFR section 180.300). Condition: During testing of a sample of seven vendors subject to AFAAC Suspension and Debarment controls, we noted two instances where there was a lack of evidence that AFAAC verified that the vendor was not suspended or debarred before entering into a covered transaction with those vendors during fiscal year 2022. We also noted two instances where the suspension and debarment check was not performed annually. Questioned Costs: None Context: Two vendors, out of our sample of seven, were found to have no evidence of verification that the vendor was not suspended or debarred. Also, two vendors were found to not have an annual verification that the vendor was not suspended or debarred. We did later verify the vendors were not suspended or debarred. Cause: Due to turnover within the procurement department, documentation supporting the performance of suspension and debarment compliance checks could not be located. Effect: Without maintaining supporting evidence that suspension and debarment procedures were performed over all applicable vendors, the Organization cannot support that the federally required procedures were performed and could potentially contract with vendors who are suspended or debarred, causing AFAAC to be out of compliance with regulations. Repeat Finding: No. Recommendation: We recommend the Organization maintain evidence of suspension and debarment procedures to support compliance to federal regulations and to ensure that all potential vendors are not suspended or debarred. Also, we recommend that the Organization expand its purchasing procedures to add suspension or debarment certification and verification to all Organization purchase orders to ensure transactions in all funds are being verified for current suspension or debarment. Views of Responsible Officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response.
Criteria or Specific Requirement: Federal regulations require recipients of federal funds to document the history of procurement transactions, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Federal regulations also specific certain procurement methods that recipients must use in certain circumstances. These regulations allow recipients to utilize a noncompetitive procurement method if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Condition: During our testing, we noted that for one out of 19 procurement transactions tested the Organization did not have documentation of the history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Questioned Costs: None Context: The history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price was not documented for one of 19 procurement transactions tested. Cause: The Organization?s procurement policy states that procurement procedures are not required for certain transactions due to the nature of the transaction. Effect: The Organization may not be in compliance with federal regulations for certain procurement transactions. Repeat Finding: No. Recommendation: We recommend that the Organization revise its procurement policy so that procurement procedures apply to all transactions using thresholds and procurement methods specified by federal regulations, and maintain documentation required by such regulations. Views of Responsible Officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response.
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires that when a non-federal entity plans to enter 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. 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 (2 CFR section 180.300). Condition: During testing of a sample of seven vendors subject to AFAAC Suspension and Debarment controls, we noted two instances where there was a lack of evidence that AFAAC verified that the vendor was not suspended or debarred before entering into a covered transaction with those vendors during fiscal year 2022. We also noted two instances where the suspension and debarment check was not performed annually. Questioned Costs: None Context: Two vendors, out of our sample of seven, were found to have no evidence of verification that the vendor was not suspended or debarred. Also, two vendors were found to not have an annual verification that the vendor was not suspended or debarred. We did later verify the vendors were not suspended or debarred. Cause: Due to turnover within the procurement department, documentation supporting the performance of suspension and debarment compliance checks could not be located. Effect: Without maintaining supporting evidence that suspension and debarment procedures were performed over all applicable vendors, the Organization cannot support that the federally required procedures were performed and could potentially contract with vendors who are suspended or debarred, causing AFAAC to be out of compliance with regulations. Repeat Finding: No. Recommendation: We recommend the Organization maintain evidence of suspension and debarment procedures to support compliance to federal regulations and to ensure that all potential vendors are not suspended or debarred. Also, we recommend that the Organization expand its purchasing procedures to add suspension or debarment certification and verification to all Organization purchase orders to ensure transactions in all funds are being verified for current suspension or debarment. Views of Responsible Officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response.
Criteria or Specific Requirement: Federal regulations require recipients of federal funds to document the history of procurement transactions, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Federal regulations also specific certain procurement methods that recipients must use in certain circumstances. These regulations allow recipients to utilize a noncompetitive procurement method if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Condition: During our testing, we noted that for one out of 19 procurement transactions tested the Organization did not have documentation of the history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Questioned Costs: None Context: The history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price was not documented for one of 19 procurement transactions tested. Cause: The Organization?s procurement policy states that procurement procedures are not required for certain transactions due to the nature of the transaction. Effect: The Organization may not be in compliance with federal regulations for certain procurement transactions. Repeat Finding: No. Recommendation: We recommend that the Organization revise its procurement policy so that procurement procedures apply to all transactions using thresholds and procurement methods specified by federal regulations, and maintain documentation required by such regulations. Views of Responsible Officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response.