Finding Number 2025-207: The Commission did not verify that vendors were not suspended or debarred prior to making federal grant payments. Federal Program: 84.126 - Rehabilitation Services - Vocational Rehabilitation Grants to States Related to Prior Finding: N/A Agency’s view: The Commission agrees...
Finding Number 2025-207: The Commission did not verify that vendors were not suspended or debarred prior to making federal grant payments. Federal Program: 84.126 - Rehabilitation Services - Vocational Rehabilitation Grants to States Related to Prior Finding: N/A Agency’s view: The Commission agrees with this finding. ICBVI recognizes the absence of vendor suspension/debarment verifications prior to payment. Corrective Action: • Verification Process: Procedures were put in place to check applicable vendors against the SAM.gov database on an annual basis. Documentation of each check will be retained and periodically reviewed. • Staff Training: Relevant staff will be trained on suspension/debarment requirements, and responsibility for checks will be clearly assigned. Laura Corazar checks that the vendor is not debarred and saves the screenshot demonstrating this. Corey Bresina will review and initial that this has been verified. Procedure as follows: Procedure: Vendor Exclusion Verification – SAM.gov Document Owner: Accounting Department Effective Date: December 1, 2025 Review Cycle: Annually, with quarterly vendor reviews Applicable Regulations: 2 CFR Part 180; 2 CFR Part 200, Subpart C, Appendix I Objective: This procedure establishes the steps for verifying that vendors, contractors, and subrecipients are not suspended, debarred, or otherwise excluded from participation in federally funded programs, in accordance with 2 CFR Part 180. It ensures federal funds are awarded only to responsible parties and provides a documented audit trail for compliance purposes. Scope: These requirements apply to all personnel involved in: • Procurement activities funded as a whole or in part with federal funds • Issuing subawards, contracts, or purchase orders under federal programs • Vendor selection, onboarding, and monitoring • Grant administration and compliance oversight All employees responsible for these functions must follow this procedure. Responsibilities: • All staff involved in procurement, grant management, or vendor selection must perform and document SAM.gov checks. This ensures we remain compliant with 2 CFR Part 180 and protect all federal funds entrusted to our organization. Procedure Steps: • Vendor Identification Gather vendor information: legal name, UEI, CAGE code, and relevant location details. • SAM.gov Exclusion Search Navigate to SAM.gov Click Search Records Select Exclusions under the Domain filter Enter vendor identifiers (Name, UEI, CAGE code, or other applicable criteria) Click Search to retrieve results • Review Results No Results: Vendor is not excluded “Entity” (green): Vendor is active and eligible “Exclusion” (purple): Vendor is suspended or debarred Do not proceed with any transaction Escalate to Administrative Services Manager Contact the issuing federal agency if clarification is needed. • Documentation Save a PDF or screenshot of the search results Record the search and outcome in the Quarterly Vendor Review Log. • Quarterly Review - All active vendors must be reviewed quarterly for exclusion status, based on federal fiscal year Maintain documentation in the designated compliance folder Accounting staff verify completion and records adherence. Recordkeeping: • Maintain PDF/screenshots of each SAM.gov search • Maintain completed Quarterly Vendor Review Logs • Retain records in accordance with federal grant record retention requirements. Non-Compliance: Failure to follow this procedure may result in: • Audit findings • Repayment of federal funds • Suspension or termination of federal awards References: • 2 CFR Part 180 – Non-Procurement Debarment and Suspension • 2 CFR Part 200, Subpart C, Appendix II – Contract Provisions for Non-Federal Entities • SAM.gov Exclusions Database. Anticipated Corrective Action Date: This was corrected in December 2025 Responsible for Corrective Action: Laura Cortazar, Financial Technician lcortazar@icbvi.idaho.gov (208) 334-3220