BGC
Berkeley Geochronology Center
2455 Ridge Rd.
Berkeley, CA 94709 USA
CORRECTIVE ACTION PLAN
September 29, 2024
National Science Foundation
Berkeley Geochronology Center respectfully submits the following corrective action plan for the
year ended March 31, 2024.
Lindquist, von Husen and Joyce...
BGC
Berkeley Geochronology Center
2455 Ridge Rd.
Berkeley, CA 94709 USA
CORRECTIVE ACTION PLAN
September 29, 2024
National Science Foundation
Berkeley Geochronology Center respectfully submits the following corrective action plan for the
year ended March 31, 2024.
Lindquist, von Husen and Joyce, LLP, 90 New Montgomery Street, 11th Floor, San Francisco,
CA 94105.
Audit period: 4/1/23 - 3/31/24
The findings from the March 31, 2024, schedule of findings and questioned costs are discussed
below. The findings are numbered consistently with the numbers assigned in the schedule.
FINDINGS-FINANCIAL STATEMENT AUDIT
MATERIAL WEAKNESS
Finding No. 2024-1 - Deficiency in controls on checking suspended and debarment status of
vendors.
Cause:
The part of BGC's grants manual where there's a requirement to check debarment is in its subawards
section, where it states that one of the grant manager's responsibilities was to validate the
debarment status of their sub-awardees. The manual does not include the requirement to check
the suspension and debarment status of vendors when procuring goods and services. Moreover,
the manual does not outline the actual process and control of validation, such as when should
BGC check the suspension and debarment status of their vendors and, what documents should
BGC maintain to support the vendor's status and control over this process.
Recommendation:
Management should consider reviewing their policies and procedures and update it to specify
that suspension and debarment status should be checked prior to purchasing or contracting with
vendors to ensure that it has not been suspended or debarred by the federal government, and not
just during the subaward process. Management can also consider including a clause in their
contracts for the requirements relating to suspension and debarment and require the contractor to
certify that it and its principals are not suspended or debarred from doing business with the
federal government.
Views of responsible officials and planned corrective actions:
The hiring of Daniel Uhlmann was funded by a National Science Foundation grant whose short
title is "Wilkes Basin". This grant was for a collaborative project with multiple institutions and
Principle Investigators. The hiring was initiated by Dr. Claire Todd on behalf of all the
collaborating institutions because she had hired him successfully for previous, similar projects in
Antarctica. Mr. Uhlman was presented to BGC as a European Mountaineer from France.
Because of his French address, we assumed that his business was French and therefore we did
not ask for proof of his not being suspended by the Federal government through a check
on SAM.gov, as required in our policy and reflected in our PO forms.
It is true that the BGC Grants Manual as well as our Accounting Manual did not state the
requirement to check for suspension and debarment. This was immediately corrected in our
Accounting Manual on which our Grant's manual is based, and a clause requiring all vendors and
their principals to certify they are not suspended or debarred from doing business with the U.S.
Federal Government will be added to all contracts starting now.
If the National Science Foundation has questions regarding this plan, please call Tania
Borostyan, Business Manager/CFO at 510-644-0299.
Sincerely yours,
Paul R. Renne
President
Berkeley Geochronology Center