Audit 406219

Condition SCORE has an established procedure requiring review of vendors in the System for Award Management (SAM.gov) to ensure vendors are not suspended or debarred prior to engagement using federal funds. During our testing of suspension and debarment for new and renewed contracts, we noted that the documentation provided as evidence that SCORE conducted the required checks did not consistently include clear evidence that vendors were verified in SAM.gov for suspension, debarment, and active registration status at the time of award or renewal. In several instances, the documentation provided lacked dated SAM.gov search results or other proof of verification, making it difficult to confirm the date the required eligibility checks were completed before obligating federal funds. Additionally, for multi-year or continuing contracts, certain vendors that were originally vetted at the time of initial engagement did not have documented evidence of a subsequent suspension and debarment verification. Criteria Federal procurement standards require non-Federal entities to: ▪ Verify that vendors are not suspended or debarred prior to entering into or renewing an agreement (2 CFR § 180 and § 200.214). ▪ Maintain complete procurement documentation, including approvals, selection methods, contract documents, and evidence of compliance with procurement rules, in accordance with Uniform Guidance procurement requirements (2 CFR § 200.318–327). A SAM.gov verification—via screenshot, printout, or automated system—is an acceptable form of documentation. Cause While SCORE has implemented procedures to verify new vendors through SAM.gov, the procedures did not explicitly require periodic verification for existing vendors whose contracts continue across multiple years or are renewed. Also, while personnel may be performing eligibility checks for new vendors, there is no standardized requirement or checklist to ensure that proof of the verification (such as dated screenshots or search results) is consistently saved. Effect As a result, the organization lacks sufficient documentary evidence to demonstrate that the required SAM.gov verifications were performed at the time of contract award or renewal. Although no vendors were identified as suspended or debarred, the absence of supporting documentation limits the organization’s ability to substantiate compliance with federal procurement requirements. Also, there is a risk that an existing vendor could become suspended or debarred after the initial contract award and continue to receive payments without updated verification. Recommendation We recommend that SCORE expand its existing vendor compliance procedures to include periodic verification of suspension and debarment status for multi-year or continuing service agreement vendors. We also recommend that management implement a standard procedure requiring documentation of dated SAM.gov verification for all vendors prior to contract award and renewal. These dated SAM.gov verifications should be retained as part of the vendor file.

Condition During our review of the client’s compliance with SBA reporting requirements, we noted that certain quarterly reports submitted (SBA Form 270) to the SBA did not reconcile to the corresponding monthly reports (Detailed Expenditure Worksheets). The quarterly SBA Form 270s which were submitted contain incomplete data which had to be subsequently amended. Criteria Under SBA federal grant reporting requirements, recipients must ensure complete and accurate financial and performance reporting, including reconciliation between monthly and quarterly submissions. Cause The procedures for reconciling quarterly reports to the underlying monthly data were not consistently performed. Effect As a result, financial information submitted to SBA was incomplete. The lack of reconciliations reduces the reliability of reported data and limits the ability to demonstrate compliance with SBA reporting requirements. This may increase the risk of reporting errors going undetected and could expose the client to questioned costs, compliance findings, or increased oversight from SBA or other regulatory authorities. Recommendation We recommend that SCORE strengthen its controls over the review and reconciliation of the quarterly and monthly reports so as to ensure that the monthly Detailed Expenditure Worksheets and related financial data agree to the quarterly submissions (SBA Form 270, SF-425) prior to filing. We also recommend that supervisory review and sign-off be documented for all monthly, quarterly, and performance reports, including reconciliations, ensuring reporting files contain a complete audit trail.