Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.
Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.