Action Item Title 2022-003 – Procurement Policies and Covered Transactions
Compliance Requirement Procurement, Suspension, and Debarment
Status (Open: In-process)
Condition:
General Procurement Standards - Written Policies – The Corporation has an outdated institutional procurement manual appr...
Action Item Title 2022-003 – Procurement Policies and Covered Transactions
Compliance Requirement Procurement, Suspension, and Debarment
Status (Open: In-process)
Condition:
General Procurement Standards - Written Policies – The Corporation has an outdated institutional procurement manual approved in 2014 that lacks written policies to ascertain compliance with the provisions of federal statutes, regulations, or the terms and conditions of federal awards regarding procurement, suspension, and debarment requirements.
Suspension and Debarment - Covered Transaction – From a population of nineteen disbursements, we selected nine disbursements to ascertain compliance with 2 CFR section 180.220 by examining the procurement documents provided by the Corporation. From that sample, we identified nine instances in which the SAM.gov registration verification process was not performed. Of the nine instances, we found eight suppliers properly registered, but one supplier appears as validated as unique and existing but not registered in SAM.gov.
Identified root cause:
Lack of understanding of procurement compliance requirements for federal awards. Fiscal year 2023 was the first year for the Corporation to be subjected to a single audit compliance requirement for receiving and expending COVID-19 public health emergency programs
Grantee resolution plan:
General Procurement Standards - Written Policies – With the implementation of Law No. 73 of 2019, previous processes established by regulation are repealed and rendered ineffective. In addition, the Corporation will adopt procurement policies in compliance with the federal regulations.
Suspension and Debarment - Covered Transaction - Currently, the Corporation is verifying and requesting all suppliers with contracts of $25,000 and over with evidence of being active at SAM.gov. Also, the Corporation is verifying if the supplier is suspended or debarred to do business with the Federal government.
Completion Date:
General Procurement Standards - Written Policies – By June 30, 2025
Suspension and Debarment - Covered Transaction – Corrected in FY2023.
Name and Title of contact:
Linnette Dávila Alemán- Financial and Budget Assistant Manager
Phone: 787-724-4747 ext. 2105
Email: ldavila@cba.pr.gov
Jetppeht Pérez de Corcho Morgado – General Manager
Phone: 787-724-4747 ext. 2102
Email: jperez@cba.pr.gov