The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...
The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)