2022 001 Suspension and Debarment National Foundation on the Arts and the Humanities: Institute of Museum and Library Services: Grants to States (ALN 45.310) Federal Award Numbers and Years: LS-246171-OLS-20 (10/1/19 ? 9/30/2021), LS-246548-OLS-20 (4/21/20 ? 9/30/21), LS-249977-OLS-21 (10/1/20 ? 9/30/22), LS-250226-OLS-21 (4/8/21 ? 9/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2021-001 Finding Type: Significant Deficiency and Noncompliance Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Additionally, in accordance with Federal requirements, the Organization shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The Organization?s policy is to check the suspension and debarment status of each vendor that enters into business with the Organization. The suspension and debarment status is verified before vendors receive any form of payment. During our testwork, we noted that for 7 of the 7 covered transactions selected for testwork, the Organization did not maintain evidence that the vendor was neither suspended nor debarred before entering into the covered transaction. However, our testwork verified that the vendors were not listed on the SAM.gov website as suspended or debarred. The Organization?s policies and procedures to ensure compliance with the above requirements was implemented during fiscal year 2022 to ensure that the documentation was maintained to ensure the suspension and debarment status was validated. However, the issues noted in this finding occurred before the policies and procedures were implemented. Cause The Organization did not have a policy to ensure documentation was maintained to validate that the suspension and debarment status was verified of each eligible vendor prior to entering the covered transaction. Effect There was no audit evidence maintained by the Organization to ensure compliance with the suspension and debarment requirements. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the Organization strengthen its policies and procedures over the suspension and debarment requirements to ensure adequate documentation is maintained for all covered transactions.
2022 001 Suspension and Debarment National Foundation on the Arts and the Humanities: Institute of Museum and Library Services: Grants to States (ALN 45.310) Federal Award Numbers and Years: LS-246171-OLS-20 (10/1/19 ? 9/30/2021), LS-246548-OLS-20 (4/21/20 ? 9/30/21), LS-249977-OLS-21 (10/1/20 ? 9/30/22), LS-250226-OLS-21 (4/8/21 ? 9/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2021-001 Finding Type: Significant Deficiency and Noncompliance Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Additionally, in accordance with Federal requirements, the Organization shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The Organization?s policy is to check the suspension and debarment status of each vendor that enters into business with the Organization. The suspension and debarment status is verified before vendors receive any form of payment. During our testwork, we noted that for 7 of the 7 covered transactions selected for testwork, the Organization did not maintain evidence that the vendor was neither suspended nor debarred before entering into the covered transaction. However, our testwork verified that the vendors were not listed on the SAM.gov website as suspended or debarred. The Organization?s policies and procedures to ensure compliance with the above requirements was implemented during fiscal year 2022 to ensure that the documentation was maintained to ensure the suspension and debarment status was validated. However, the issues noted in this finding occurred before the policies and procedures were implemented. Cause The Organization did not have a policy to ensure documentation was maintained to validate that the suspension and debarment status was verified of each eligible vendor prior to entering the covered transaction. Effect There was no audit evidence maintained by the Organization to ensure compliance with the suspension and debarment requirements. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the Organization strengthen its policies and procedures over the suspension and debarment requirements to ensure adequate documentation is maintained for all covered transactions.
2022 001 Suspension and Debarment National Foundation on the Arts and the Humanities: Institute of Museum and Library Services: Grants to States (ALN 45.310) Federal Award Numbers and Years: LS-246171-OLS-20 (10/1/19 ? 9/30/2021), LS-246548-OLS-20 (4/21/20 ? 9/30/21), LS-249977-OLS-21 (10/1/20 ? 9/30/22), LS-250226-OLS-21 (4/8/21 ? 9/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2021-001 Finding Type: Significant Deficiency and Noncompliance Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Additionally, in accordance with Federal requirements, the Organization shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The Organization?s policy is to check the suspension and debarment status of each vendor that enters into business with the Organization. The suspension and debarment status is verified before vendors receive any form of payment. During our testwork, we noted that for 7 of the 7 covered transactions selected for testwork, the Organization did not maintain evidence that the vendor was neither suspended nor debarred before entering into the covered transaction. However, our testwork verified that the vendors were not listed on the SAM.gov website as suspended or debarred. The Organization?s policies and procedures to ensure compliance with the above requirements was implemented during fiscal year 2022 to ensure that the documentation was maintained to ensure the suspension and debarment status was validated. However, the issues noted in this finding occurred before the policies and procedures were implemented. Cause The Organization did not have a policy to ensure documentation was maintained to validate that the suspension and debarment status was verified of each eligible vendor prior to entering the covered transaction. Effect There was no audit evidence maintained by the Organization to ensure compliance with the suspension and debarment requirements. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the Organization strengthen its policies and procedures over the suspension and debarment requirements to ensure adequate documentation is maintained for all covered transactions.
2022 001 Suspension and Debarment National Foundation on the Arts and the Humanities: Institute of Museum and Library Services: Grants to States (ALN 45.310) Federal Award Numbers and Years: LS-246171-OLS-20 (10/1/19 ? 9/30/2021), LS-246548-OLS-20 (4/21/20 ? 9/30/21), LS-249977-OLS-21 (10/1/20 ? 9/30/22), LS-250226-OLS-21 (4/8/21 ? 9/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2021-001 Finding Type: Significant Deficiency and Noncompliance Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Additionally, in accordance with Federal requirements, the Organization shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The Organization?s policy is to check the suspension and debarment status of each vendor that enters into business with the Organization. The suspension and debarment status is verified before vendors receive any form of payment. During our testwork, we noted that for 7 of the 7 covered transactions selected for testwork, the Organization did not maintain evidence that the vendor was neither suspended nor debarred before entering into the covered transaction. However, our testwork verified that the vendors were not listed on the SAM.gov website as suspended or debarred. The Organization?s policies and procedures to ensure compliance with the above requirements was implemented during fiscal year 2022 to ensure that the documentation was maintained to ensure the suspension and debarment status was validated. However, the issues noted in this finding occurred before the policies and procedures were implemented. Cause The Organization did not have a policy to ensure documentation was maintained to validate that the suspension and debarment status was verified of each eligible vendor prior to entering the covered transaction. Effect There was no audit evidence maintained by the Organization to ensure compliance with the suspension and debarment requirements. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the Organization strengthen its policies and procedures over the suspension and debarment requirements to ensure adequate documentation is maintained for all covered transactions.
2022 001 Suspension and Debarment National Foundation on the Arts and the Humanities: Institute of Museum and Library Services: Grants to States (ALN 45.310) Federal Award Numbers and Years: LS-246171-OLS-20 (10/1/19 ? 9/30/2021), LS-246548-OLS-20 (4/21/20 ? 9/30/21), LS-249977-OLS-21 (10/1/20 ? 9/30/22), LS-250226-OLS-21 (4/8/21 ? 9/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2021-001 Finding Type: Significant Deficiency and Noncompliance Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Additionally, in accordance with Federal requirements, the Organization shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The Organization?s policy is to check the suspension and debarment status of each vendor that enters into business with the Organization. The suspension and debarment status is verified before vendors receive any form of payment. During our testwork, we noted that for 7 of the 7 covered transactions selected for testwork, the Organization did not maintain evidence that the vendor was neither suspended nor debarred before entering into the covered transaction. However, our testwork verified that the vendors were not listed on the SAM.gov website as suspended or debarred. The Organization?s policies and procedures to ensure compliance with the above requirements was implemented during fiscal year 2022 to ensure that the documentation was maintained to ensure the suspension and debarment status was validated. However, the issues noted in this finding occurred before the policies and procedures were implemented. Cause The Organization did not have a policy to ensure documentation was maintained to validate that the suspension and debarment status was verified of each eligible vendor prior to entering the covered transaction. Effect There was no audit evidence maintained by the Organization to ensure compliance with the suspension and debarment requirements. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the Organization strengthen its policies and procedures over the suspension and debarment requirements to ensure adequate documentation is maintained for all covered transactions.
2022 001 Suspension and Debarment National Foundation on the Arts and the Humanities: Institute of Museum and Library Services: Grants to States (ALN 45.310) Federal Award Numbers and Years: LS-246171-OLS-20 (10/1/19 ? 9/30/2021), LS-246548-OLS-20 (4/21/20 ? 9/30/21), LS-249977-OLS-21 (10/1/20 ? 9/30/22), LS-250226-OLS-21 (4/8/21 ? 9/30/22) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2021-001 Finding Type: Significant Deficiency and Noncompliance Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Additionally, in accordance with Federal requirements, the Organization shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The Organization?s policy is to check the suspension and debarment status of each vendor that enters into business with the Organization. The suspension and debarment status is verified before vendors receive any form of payment. During our testwork, we noted that for 7 of the 7 covered transactions selected for testwork, the Organization did not maintain evidence that the vendor was neither suspended nor debarred before entering into the covered transaction. However, our testwork verified that the vendors were not listed on the SAM.gov website as suspended or debarred. The Organization?s policies and procedures to ensure compliance with the above requirements was implemented during fiscal year 2022 to ensure that the documentation was maintained to ensure the suspension and debarment status was validated. However, the issues noted in this finding occurred before the policies and procedures were implemented. Cause The Organization did not have a policy to ensure documentation was maintained to validate that the suspension and debarment status was verified of each eligible vendor prior to entering the covered transaction. Effect There was no audit evidence maintained by the Organization to ensure compliance with the suspension and debarment requirements. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the Organization strengthen its policies and procedures over the suspension and debarment requirements to ensure adequate documentation is maintained for all covered transactions.