Audit 410857

Finding: 2025-002 Procurement, Suspension and Debarment Federal Agency(ies): United States Department of Defense Federal Program(s): Research and Development Cluster Assistance Listing Number(s): 12.300, 12.330 Pass-through Entity (if applicable): Direct awards and pass-through awards from RTI International and Greensight, Inc. Award Identification Number and Year: Various Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR 200.317 through 2 CFR 200.327, non-Federal entities are required to maintain documentation sufficient to detail the history of procurement transactions. Such documentation should include, as applicable, the rationale for the method of procurement, contractor selection, basis for contract price, and the basis for any sole-source procurement. Additionally, pursuant to 2 CFR 180 and 2 CFR 200.214, non-Federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred and should maintain documentation demonstrating that applicable vendors were screened prior to contracting or payment. Condition: As part of our testing of vendor expenditures charged to Federal awards within the Research and Development Cluster, we selected a statistical sample of procurement transactions and noted deficiencies in RoboNation's procurement and suspension and debarment documentation. Specifically, we noted instances in which RoboNation did not consistently document the rationale supporting its selection of vendors charged to Federal awards. In addition, for procurements utilizing a sole-source or noncompetitive procurement methodology, RoboNation did not consistently document which of the allowable exceptions under 2 CFR 200.320 justified the use of noncompetitive procurement. With respect to suspension and debarment requirements, we noted that RoboNation did not consistently maintain evidence that vendors were screened against the System for Award Management (SAM.gov) database prior to contracting or payment. We also identified instances in which SAM.gov screening reports were either undated or dated after execution of the vendor agreement and related payment activity. Cause: RoboNation's policies and procedures for procurement documentation and suspension and debarment compliance were not operating effectively. Specifically, controls were not sufficient to ensure that procurement files contained required support for vendor selection and sole-source procurements, nor were controls adequate to ensure that SAM.gov screenings were completed and documented prior to engaging vendors charged to Federal awards. Effect or Potential Effect: The lack of adequate procurement and suspension and debarment documentation increases the risk that procurement transactions may not comply with Uniform Guidance requirements and that vendors could be selected without sufficient support for the procurement method utilized. Additionally, the lack of timely and documented SAM.gov screenings increases the risk that Federal funds could be expended on vendors that are suspended or debarred from participation in Federally funded programs. Questioned Costs: $437,591 Context: As part of our testing of the Procurement, Suspension, and Debarment compliance requirements for the Research and Development Cluster, we selected a statistical sample of vendor transactions charged to Federal awards during the year ended December 31, 2025. Identification as a Repeat Finding, if Applicable: Yes, repeat of 2024-003. Recommendation: We recommend that management strengthen controls over procurement and suspension and debarment compliance by implementing procedures requiring procurement files to contain documentation supporting vendor selection, the procurement method utilized, and, when applicable, the specific basis for sole-source procurement under Uniform Guidance. In addition, management should establish procedures to ensure that SAM.gov screenings are performed and documented prior to contract execution or payment and that evidence of such screenings is retained within the procurement file.

Finding: 2025-003 Timely Submission of the Data Collection Form (DCF) to the Federal Audit Clearinghouse Federal Agency(ies): United States Department of Defense Federal Program(s): Research and Development Cluster Assistance Listing Number(s): 12.300, 12.330 Pass-through Entity (if applicable): Direct awards and pass-through awards from RTI International and Greensight, Inc. Award Identification Number and Year: Various Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to 2 CFR 200.512, a non-Federal entity that expends $1,000,000 or more in Federal awards during its fiscal year is required to submit the Single Audit reporting package, including the Data Collection Form (DCF), to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor's reports or nine months after the end of the audit period. For the fiscal year ended December 31, 2024, the Organization was required to submit its reporting package and Data Collection Form no later than September 30, 2025. Condition: RoboNation did not timely submit its Single Audit reporting package and Data Collection Form for the fiscal year ended December 31, 2024. Fieldwork for the fiscal year 2024 Single Audit was not scheduled to begin until after the September 30, 2025 filing deadline. Cause: RoboNation did not maintain effective controls to monitor and ensure timely completion of the annual Single Audit process and submission of required reporting to the Federal Audit Clearinghouse. Specifically, procedures were not in place to monitor filing deadlines, coordinate audit completion activities, and ensure that required Federal reporting was submitted within the timeframe prescribed by Uniform Guidance. Effect or Potential Effect: RoboNation was not in compliance with the reporting requirements of Uniform Guidance. Untimely submission of the Single Audit reporting package may limit the ability of Federal agencies and pass-through entities to perform timely oversight of Federal awards and increases the risk of sanctions or additional monitoring by Federal awarding agencies. Questioned Costs: N/A Context: RoboNation was required to submit one Data Collection Form and reporting package related to its fiscal year ended December 31, 2024. The submission was made several months after the required deadline. Identification as a Repeat Finding, if Applicable: Yes, repeat of 2024-004. Recommendation: We recommend that management implement procedures to monitor all Single Audit reporting deadlines and establish a formal timeline for financial statement preparation, audit completion, review, and submission of the reporting package to the Federal Audit Clearinghouse. Management should periodically monitor progress against these deadlines throughout the year to ensure compliance with Uniform Guidance reporting requirements.