Audit 412698

FY End
2025-12-31
Total Expended
$44.59M
Findings
158
Programs
14
Organization: The Geneva Foundation (WA)
Year: 2025 Accepted: 2026-09-29

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
1237770 2025-001 Material Weakness Yes I
1237771 2025-002 Material Weakness Yes I
1237772 2025-003 Material Weakness Yes I
1237773 2025-004 Material Weakness Yes I
1237774 2025-005 Material Weakness Yes I
1237775 2025-006 Material Weakness Yes I
1237776 2025-007 Material Weakness Yes I
1237777 2025-008 Material Weakness Yes I
1237778 2025-009 Material Weakness Yes I
1237779 2025-010 Material Weakness Yes I
1237780 2025-011 Material Weakness Yes I
1237781 2025-012 Material Weakness Yes I
1237782 2025-013 Material Weakness Yes I
1237783 2025-014 Material Weakness Yes I
1237784 2025-015 Material Weakness Yes I
1237785 2025-016 Material Weakness Yes I
1237786 2025-017 Material Weakness Yes I
1237787 2025-018 Material Weakness Yes I
1237788 2025-019 Material Weakness Yes I
1237789 2025-020 Material Weakness Yes I
1237790 2025-021 Material Weakness Yes I
1237791 2025-022 Material Weakness Yes I
1237792 2025-023 Material Weakness Yes I
1237793 2025-024 Material Weakness Yes I
1237794 2025-025 Material Weakness Yes I
1237795 2025-026 Material Weakness Yes I
1237796 2025-027 Material Weakness Yes I
1237797 2025-028 Material Weakness Yes I
1237798 2025-029 Material Weakness Yes I
1237799 2025-030 Material Weakness Yes I
1237800 2025-031 Material Weakness Yes I
1237801 2025-032 Material Weakness Yes I
1237802 2025-033 Material Weakness Yes I
1237803 2025-034 Material Weakness Yes I
1237804 2025-035 Material Weakness Yes I
1237805 2025-036 Material Weakness Yes I
1237806 2025-037 Material Weakness Yes I
1237807 2025-038 Material Weakness Yes I
1237808 2025-039 Material Weakness Yes I
1237809 2025-040 Material Weakness Yes I
1237810 2025-041 Material Weakness Yes I
1237811 2025-042 Material Weakness Yes I
1237812 2025-043 Material Weakness Yes I
1237813 2025-044 Material Weakness Yes I
1237814 2025-045 Material Weakness Yes I
1237815 2025-046 Material Weakness Yes I
1237816 2025-047 Material Weakness Yes I
1237817 2025-048 Material Weakness Yes I
1237818 2025-049 Material Weakness Yes I
1237819 2025-050 Material Weakness Yes I
1237820 2025-051 Material Weakness Yes I
1237821 2025-052 Material Weakness Yes I
1237822 2025-053 Material Weakness Yes I
1237823 2025-054 Material Weakness Yes I
1237824 2025-055 Material Weakness Yes I
1237825 2025-056 Material Weakness Yes I
1237826 2025-057 Material Weakness Yes I
1237827 2025-058 Material Weakness Yes I
1237828 2025-059 Material Weakness Yes I
1237829 2025-060 Material Weakness Yes I
1237830 2025-061 Material Weakness Yes I
1237831 2025-062 Material Weakness Yes I
1237832 2025-063 Material Weakness Yes I
1237833 2025-064 Material Weakness Yes I
1237834 2025-065 Material Weakness Yes I
1237835 2025-066 Material Weakness Yes I
1237836 2025-067 Material Weakness Yes I
1237837 2025-068 Material Weakness Yes I
1237838 2025-069 Material Weakness Yes I
1237839 2025-070 Material Weakness Yes I
1237840 2025-071 Material Weakness Yes I
1237841 2025-072 Material Weakness Yes I
1237842 2025-073 Material Weakness Yes I
1237843 2025-074 Material Weakness Yes I
1237844 2025-075 Material Weakness Yes I
1237845 2025-076 Material Weakness Yes I
1237846 2025-077 Material Weakness Yes I
1237847 2025-078 Material Weakness Yes I
1237848 2025-079 Material Weakness Yes I
1237849 2025-080 Material Weakness Yes I
1237850 2025-081 Material Weakness Yes I
1237851 2025-082 Material Weakness Yes I
1237852 2025-083 Material Weakness Yes I
1237853 2025-084 Material Weakness Yes I
1237854 2025-085 Material Weakness Yes I
1237855 2025-086 Material Weakness Yes I
1237856 2025-087 Material Weakness Yes I
1237857 2025-088 Material Weakness Yes I
1237858 2025-089 Material Weakness Yes I
1237859 2025-090 Material Weakness Yes I
1237860 2025-091 Material Weakness Yes I
1237861 2025-092 Material Weakness Yes I
1237862 2025-093 Material Weakness Yes I
1237863 2025-094 Material Weakness Yes I
1237864 2025-095 Material Weakness Yes I
1237865 2025-096 Material Weakness Yes I
1237866 2025-097 Material Weakness Yes I
1237867 2025-098 Material Weakness Yes I
1237868 2025-099 Material Weakness Yes I
1237869 2025-100 Material Weakness Yes I
1237870 2025-101 Material Weakness Yes I
1237871 2025-102 Material Weakness Yes I
1237872 2025-103 Material Weakness Yes I
1237873 2025-104 Material Weakness Yes I
1237874 2025-105 Material Weakness Yes I
1237875 2025-106 Material Weakness Yes I
1237876 2025-107 Material Weakness Yes I
1237877 2025-108 Material Weakness Yes I
1237878 2025-109 Material Weakness Yes I
1237879 2025-110 Material Weakness Yes I
1237880 2025-111 Material Weakness Yes I
1237881 2025-112 Material Weakness Yes I
1237882 2025-113 Material Weakness Yes I
1237883 2025-114 Material Weakness Yes I
1237884 2025-115 Material Weakness Yes I
1237885 2025-116 Material Weakness Yes I
1237886 2025-117 Material Weakness Yes I
1237887 2025-118 Material Weakness Yes I
1237888 2025-119 Material Weakness Yes I
1237889 2025-120 Material Weakness Yes I
1237890 2025-121 Material Weakness Yes I
1237891 2025-122 Material Weakness Yes I
1237892 2025-123 Material Weakness Yes I
1237893 2025-124 Material Weakness Yes I
1237894 2025-125 Material Weakness Yes I
1237895 2025-126 Material Weakness Yes I
1237896 2025-127 Material Weakness Yes I
1237897 2025-128 Material Weakness Yes I
1237898 2025-129 Material Weakness Yes I
1237899 2025-130 Material Weakness Yes I
1237900 2025-131 Material Weakness Yes I
1237901 2025-132 Material Weakness Yes I
1237902 2025-133 Material Weakness Yes I
1237903 2025-134 Material Weakness Yes I
1237904 2025-135 Material Weakness Yes I
1237905 2025-136 Material Weakness Yes I
1237906 2025-137 Material Weakness Yes I
1237907 2025-138 Material Weakness Yes I
1237908 2025-139 Material Weakness Yes I
1237909 2025-140 Material Weakness Yes I
1237910 2025-141 Material Weakness Yes I
1237911 2025-142 Material Weakness Yes I
1237912 2025-143 Material Weakness Yes I
1237913 2025-144 Material Weakness Yes I
1237914 2025-145 Material Weakness Yes I
1237915 2025-146 Material Weakness Yes I
1237916 2025-147 Material Weakness Yes I
1237917 2025-148 Material Weakness Yes I
1237918 2025-149 Material Weakness Yes I
1237919 2025-150 Material Weakness Yes I
1237920 2025-151 Material Weakness Yes I
1237921 2025-152 Material Weakness Yes I
1237922 2025-153 Material Weakness Yes I
1237923 2025-154 Material Weakness Yes I
1237924 2025-155 Material Weakness Yes I
1237925 2025-156 Material Weakness Yes I
1237926 2025-157 Material Weakness Yes I
1237927 2025-158 Material Weakness Yes I

Contacts

Name Title Type
TR9RX33188T4 Matt Rueckert Auditee
3017883356 Samantha Strejcek Auditor
No contacts on file

Notes to SEFA

The accompanying schedule of expenditures of federal awards (Schedule) includes the federal award activity of The Geneva Foundation (Foundation) under programs of the federal government for the year ended December 31, 2025. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Foundation, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Foundation.

Finding Details

FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.
FINDING: 2025-001 - Suspension and Debarment Federal Program: Research and Development Cluster – Various ALNs Federal Agency: U.S Department of Defense and U.S. Department of Health and Human Services Statement of Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Foundation did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Foundation entering into covered transactions with entities that are suspended and debarred which is not allowed under the Research and Development Cluster. Although no actual noncompliance was identified during our procedures, the lack of documented verification represents a deficiency in internal control over compliance that could adversely affect the Foundation's ability to comply with suspension and debarment requirements. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Foundation consistently apply written procedures to verify, prior to executing any covered transaction expected to equal or exceed $25,000, that the prospective contractor is not suspended, debarred, or otherwise excluded. The Foundation should document its verification by retaining a dated SAM.gov exclusion search printout (or equivalent screenshot), obtaining a certification from the contractor, or including an appropriate suspension and debarment clause in the agreement. Evidence of the review and approval should be retained in the procurement file to demonstrate compliance. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.