Audit 408201

Finding 2025-001 - Procurement, Suspension and Debarment Controls over Compliance - Significant Deficiency Federal Agency: U.S. Department of State Federal Program: Professional and Cultural Exchange Programs Assistance Listing Number: 19.415 Pass-through Entity: American Councils for International Education Award Identification Number and Year: S-ECAGD-24-CA-0528 Criteria or Specific Requirement: The procurement standards included in the Uniform Guidance were revised effective on October 1, 2024, and the revisions were applicable to ACYPL's Federal financial assistance for the year ended December 31, 2025. In addition, Federal regulations prohibit non-Federal entities from entering into covered transactions with parties that are suspended or debarred from participating in Federal programs. The auditee is required to verify that vendors, contractors, and subrecipients subject to suspension and debarment requirements are excluded from participation in federally funded programs by checking SAM.gov, obtaining certifications, or including suspension and debarment clauses in agreements, as applicable. Such verifications are required to occur at contract inception and annually thereafter for vendors and contractors with awards in excess of $25,000 and for all subrecipients regardless of the award amount. Condition: ACYPL has not updated its procurement policy to align with the revised procurement guidelines in the Uniform Guidance. In addition, during our audit testing we noted 6 covered transactions in our sample (contract was in excess of $25,000). For two of the vendors, we noted that ACYPL did not maintain evidence of SAM exclusion verification either at contract inception or annually thereafter. However, such verifications were performed after the fact during the audit and it was noted that the two vendors were not suspended, debarred or otherwise excluded from participation in Federal programs. Cause: The procurement policy needs to be updated for the procurement standards in the revised Uniform Guidance and the policy also needs to specify when SAM verification should be performed. Effect or Potential Effect: ACYPL may enter into contracts with vendors that do not follow the current procurement standards in the revised Uniform Guidance and ACYPL may have covered transactions with suspended or debarred entities, resulting in an increased risk of noncompliance with Federal requirements. Questioned Costs: None Context: The procurement policy needs to be updated and two of six vendors in our testing sample lacked evidence that a SAM exclusion check was performed by ACYPL. Identification as a Repeat Finding, if Applicable: No. Recommendation: We recommend that management update the procurement policy to follow the procurement guidelines in the revised Uniform Guidance. The revised procurement policy should also establish and document formal procedures requiring SAM verification prior to entering into all covered transactions and annually thereafter. Evidence of the SAM verification should be maintained in vendor files.