Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, in fiscal year 2022, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they ...
Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, in fiscal year 2022, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they are not in suspension or debarment. Us Helping Us acknowledges the audit finding regarding our organization’s inconsistent application of suspension and debarment screening procedures for vendors, suppliers, and contractors paid with Federal funds. We understand that compliance with 2 CFR Part 180 and 2 CFR § 200.214 is essential to ensure Federal funds are not awarded to parties that are suspended or debarred from doing business with the Federal Government. To further address this issue and prevent recurrence, Us Helping Us will implement the following measures: establishing a Standard Operating Procedure (SOP) for suspension and debarment checks, including when and how to perform them; integrated screening into the procurement workflow, requiring verification prior to contract execution or payment, designated staff responsible for performing and documenting checks using the System for Award Management (SAM.gov). Us Helping Us will now use one or more of the following Federally accepted methods for each covered transaction: SAM.gov search with screenshot documentation, Signed certification from the vendor affirming they are not suspended or debarred, and a Contract clause stating the vendor is not suspended or debarred, included in all Federally funded agreements. Training and Oversight will be provided to staff so that team members involved in procurement and grant management have received training on suspension and debarment requirements. An annual refresher training will be provided to ensure continued compliance. Internal audits will include a review of suspension and debarment documentation for all Federally funded transactions to ensure adherence. Our procurement policy has been updated to reflect mandatory suspension and debarment checks for all covered transactions, required documentation retention for audit purposes and procedures for verifying subrecipients and professional service providers. Us Helping Us is committed to maintaining full compliance with Federal regulations and ensuring that Federal funds are only awarded to eligible entities. Us Helping Us maintains documentation of these searches, retain them in vendor files. Screenings will be conducted on an annual basis. Retrospective screenings were conducted as requested during the audit. In addition to access to SAM.gov, Us Helping Us is using the services of Office of Inspector General (OIG) Exclusion Search and Software Company. Services provided include OIG Searches as well as SAM and State Exclusion searches. Us Helping Us staff will be educated about these procedures.The Executive Director and the Deputy Executive Director for Finance and Administration, Finance and Administration are responsible for developing, implementing, and maintaining the Plan, which is currently in place and any enhancements will be effective immediately.