Audit Finding Reference: 2024-002 (Procurement, Suspension and Debarment, and Build America, Buy America) Planned Corrective Action: Certain and key contracts were executed prior to the execution of the related U.S. Department of Housing and Urban Development: Federal Assistance Listing #14.251 – Ec...
Audit Finding Reference: 2024-002 (Procurement, Suspension and Debarment, and Build America, Buy America) Planned Corrective Action: Certain and key contracts were executed prior to the execution of the related U.S. Department of Housing and Urban Development: Federal Assistance Listing #14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants awards or contained clerical omissions, resulting in the absence of suspension and debarment verification, BABA clauses, or documentation in some agreements. These issues have since been corrected—NUL amended or executed contracts in 2025 to include the required suspension and debarment provisions, incorporated BABA requirements where applicable, and obtained contractor representations to ensure compliance. While, the amendments occurred after the initial execution of the contract, NUL has taken the necessary effort to include this language in all contracts, regardless of funded with federal funds or not. To prevent recurrence, NUL will: • Perform and document SAM.gov suspension and debarment check prior to contract execution, • Incorporate suspension and debarment clauses and BABA provisions into all applicable contracts at the outset, • Use a contract compliance checklist to ensure all required federal clauses are present before execution, and • Provide staff training and implement a centralized tracking system to monitor compliance. NUL remains committed to maintaining strong internal controls and ensuring full compliance with federal reporting and procurement requirements.