Reporting a determination that an applicant is not qualified for a Federal award.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001 Identification of the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The Uniform Guidance 2 CFR Section 200.213 states, "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities". Condition: We noted the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Sanford. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Sanford relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) To ensure compliance with 2 CFR Section 200.213, Sanford conducts both preventive and detective controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Sanford transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Subsequent to vendor setup, Sanford also monitors the status of its vendors to ensure the vendor's status has not changed. Sanford does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred. (c) Sanford did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Sanford to the third-party vendor. Cause: Sanford utilizes a third-party vendor to perform suspension and debarment checks on its vendors, both during the vendor setup process as well as ongoing monitoring of active vendors. Sanford did not add an additional validation control to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match Sanford did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the system if the vendor check resulted in no match with the suspension and debarment database indicating the vendor is not suspended or debarred. In addition, Sanford did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed for ongoing monitoring purposes between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Sanford's screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Sanford from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: $0 Context: The federal portion of expenditures subject to suspension and debarment was approximately $1,300,000, which represents approximately 10% of the Research and Development Cluster federal expenditures, of which no vendors were determined to be suspended or debarred. The total amount reported on the SEFA for R&D cluster is $13,361,367. Identification as a repeat finding, if applicable: Not applicable Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for "new" vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to vendors that are suspended or disbarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventive and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process.
Finding 2022-001: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 98.001 Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Under 2 CFR ?200.213, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: It is our understanding that the Organization only includes self-certification paragraphs in all vendor contracts. The Organization did not, however, in any instance, perform screenings on its potential or current vendors, suppliers, contractors or non-domestic employees that were paid with Federal funds. Cause: The Organization does not have a formal internal policy with respect to screening vendors, suppliers, contractors or non-domestic employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors, and non-domestic employees increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Organization's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that management develop and implement a formal policy regarding when suspension and debarment checks are conducted, and when a self-certification is sufficient. This policy should include a threshold, generally $25,000, for when vendors, suppliers, contractors or non-domestic employees should be screened. All screenings should be conducted prior to signing a contract or issuing payment.
2022-002 Federal Agency: Department of Agriculture (USDA) Pass-Through Entity: State of New York Executive Department of General Services Assistance Listing Numbers: 10.568 , 10.569 Pass-through Grant Numbers: 4NY810809, 4NY100105, 4NY430803, 8NY200100 Program Name: The Emergency Food Assistance Program (TEFAP), Food Distribution Cluster Criteria: : 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted the following: - The contractors utilized by the Food Bank in 2022 were not properly checked for compliance requirements regarding debarment. They did not have a control in place to ensure the contractors used for their covered transactions were not made with a debarred or suspended party. Cause: The Food Bank did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Effect: The Food Bank is not in compliance with 2 CFR Section 200.213. The Food Bank is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the Food Bank could be overpaying for goods and services. Questioned Costs: None Context/Sampling: The Food Bank performed a subsequent review of all vendors paid with federal dollars under the major program, noting none of the vendors used were precluded from being paid with federal dollars. Repeat Finding: No Recommendation: We recommend that the Food Bank review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. View of Responsible Officials: Management agrees with the finding and will implement the recommendations.
2022-002 Federal Agency: Department of Agriculture (USDA) Pass-Through Entity: State of New York Executive Department of General Services Assistance Listing Numbers: 10.568 , 10.569 Pass-through Grant Numbers: 4NY810809, 4NY100105, 4NY430803, 8NY200100 Program Name: The Emergency Food Assistance Program (TEFAP), Food Distribution Cluster Criteria: : 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted the following: - The contractors utilized by the Food Bank in 2022 were not properly checked for compliance requirements regarding debarment. They did not have a control in place to ensure the contractors used for their covered transactions were not made with a debarred or suspended party. Cause: The Food Bank did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Effect: The Food Bank is not in compliance with 2 CFR Section 200.213. The Food Bank is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the Food Bank could be overpaying for goods and services. Questioned Costs: None Context/Sampling: The Food Bank performed a subsequent review of all vendors paid with federal dollars under the major program, noting none of the vendors used were precluded from being paid with federal dollars. Repeat Finding: No Recommendation: We recommend that the Food Bank review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. View of Responsible Officials: Management agrees with the finding and will implement the recommendations.
2022-002 Federal Agency: Department of Agriculture (USDA) Pass-Through Entity: State of New York Executive Department of General Services Assistance Listing Numbers: 10.568 , 10.569 Pass-through Grant Numbers: 4NY810809, 4NY100105, 4NY430803, 8NY200100 Program Name: The Emergency Food Assistance Program (TEFAP), Food Distribution Cluster Criteria: : 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted the following: - The contractors utilized by the Food Bank in 2022 were not properly checked for compliance requirements regarding debarment. They did not have a control in place to ensure the contractors used for their covered transactions were not made with a debarred or suspended party. Cause: The Food Bank did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Effect: The Food Bank is not in compliance with 2 CFR Section 200.213. The Food Bank is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the Food Bank could be overpaying for goods and services. Questioned Costs: None Context/Sampling: The Food Bank performed a subsequent review of all vendors paid with federal dollars under the major program, noting none of the vendors used were precluded from being paid with federal dollars. Repeat Finding: No Recommendation: We recommend that the Food Bank review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. View of Responsible Officials: Management agrees with the finding and will implement the recommendations.
2022-002 Federal Agency: Department of Agriculture (USDA) Pass-Through Entity: State of New York Executive Department of General Services Assistance Listing Numbers: 10.568 , 10.569 Pass-through Grant Numbers: 4NY810809, 4NY100105, 4NY430803, 8NY200100 Program Name: The Emergency Food Assistance Program (TEFAP), Food Distribution Cluster Criteria: : 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted the following: - The contractors utilized by the Food Bank in 2022 were not properly checked for compliance requirements regarding debarment. They did not have a control in place to ensure the contractors used for their covered transactions were not made with a debarred or suspended party. Cause: The Food Bank did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Effect: The Food Bank is not in compliance with 2 CFR Section 200.213. The Food Bank is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the Food Bank could be overpaying for goods and services. Questioned Costs: None Context/Sampling: The Food Bank performed a subsequent review of all vendors paid with federal dollars under the major program, noting none of the vendors used were precluded from being paid with federal dollars. Repeat Finding: No Recommendation: We recommend that the Food Bank review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. View of Responsible Officials: Management agrees with the finding and will implement the recommendations.
2022-002 Federal Agency: Department of Agriculture (USDA) Pass-Through Entity: State of New York Executive Department of General Services Assistance Listing Numbers: 10.568 , 10.569 Pass-through Grant Numbers: 4NY810809, 4NY100105, 4NY430803, 8NY200100 Program Name: The Emergency Food Assistance Program (TEFAP), Food Distribution Cluster Criteria: : 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our testing, we noted the following: - The contractors utilized by the Food Bank in 2022 were not properly checked for compliance requirements regarding debarment. They did not have a control in place to ensure the contractors used for their covered transactions were not made with a debarred or suspended party. Cause: The Food Bank did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Effect: The Food Bank is not in compliance with 2 CFR Section 200.213. The Food Bank is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the Food Bank could be overpaying for goods and services. Questioned Costs: None Context/Sampling: The Food Bank performed a subsequent review of all vendors paid with federal dollars under the major program, noting none of the vendors used were precluded from being paid with federal dollars. Repeat Finding: No Recommendation: We recommend that the Food Bank review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. View of Responsible Officials: Management agrees with the finding and will implement the recommendations.
Finding 2022-002 ? Procurement and Suspension and Debarment Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services Pass-Through Entities: Ohio Department of Health Assistance Listing No: 93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Award Period: 2022 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? The Uniform Guidance 2 CFR Section 200.213 states, ?Non-federal entities are subject to the non- procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities?. Condition: We identified the following matters during our testing of suspension and debarment control processes: (a) A third-party vendor performed the suspension and debarment validation process for Akron Children?s. The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. Akron Children?s relied on the suspension and debarment checks performed by the third-party vendor for results concluding no match without completing a validation control to ensure the results provided by the third party were accurate. (b) Akron Children?s conducts preventive controls in its vendor setup and monitoring process to ensure new vendors and active vendors are not suspended or debarred. A consistent vendor setup process is followed for each new vendor that Akron Children?s transacts with, regardless of whether the vendor transactions are funded through federal grant funding or through other sources. To prevent a suspended or debarred vendor from being added as a new vendor, the vendor is checked against the suspension and debarment database electronically before completion of the vendor setup. Akron Children?s does not retain the supporting documentation that the vendor setup check resulted in no match in the suspension and debarment database indicating the vendor is not suspended or debarred (c) Akron Children?s did not retain the supporting documentation of the reconciliation of the vendor list that is received from the third-party vendor that is used to perform the suspension and debarment checks after the suspension and debarment checks are performed to ensure the listing is complete and agrees to the vendor list provided by Akron Children?s to the third-party vendor. Cause: Akron Children?s does not have policies and procedures that require a validation of the third party?s controls be performed to ensure that the suspension and debarment checks performed by the third-party vendor aligned with the governmental suspension and debarment database when the search resulted in no match. Akron Children?s did not have policies and procedures in place to require that documentation is retained of its suspension and debarment checks performed when a new vendor is set up in the procurement system. In addition, Akron Children?s did not have policies and procedures in place to require that documentation is retained to support the reconciliations performed between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. Effect or potential effect: Akron Children?s screening for suspension and debarment through the third-party vendor results may not be accurate. By failing to retain the documentation of the reconciliation of vendor files to the third-party vendor search results, sufficient evidence was not retained to prove that the reconciliation took place. As a result, there was not sufficient evidence to validate the appropriate internal controls took place to prevent Akron Children?s from transacting with a vendor that was suspended or debarred, which was ultimately charged to a federal program. Questioned costs: None. Context: The federal portion of expenditures subject to suspension and debarment represents approximately 16% of total federal expenditures for the program of $1,085,801 for the year ended December 31, 2022. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should add controls to validate the accuracy of the suspension and debarment search results performed by the third-party vendor when the search results in no match. Management should implement documentation retention processes to provide evidence over the suspension and debarment search for ?new? vendors. In addition, management should implement documentation retention processes over the reconciliation between the vendor list sent to the third-party vendor to document completeness of the suspension and debarment check. Views of responsible officials: The third-party vendor used for this service does not have a system and organizational controls report available that would have been relevant to this requirement. Therefore, Akron Children?s will implement a periodic independent review of a sample of vendors sent to the third-party vendor to ensure that the processes employed by third-party vendor are accurate. Akron Children?s will also develop a retention process for all vendor searches and file submissions to evidence compliance with the Federal regulations. Further, a contract management system has been installed in 2023 that holds the validation of new vendors as acceptable for federal procurements.
Finding 2022-008 Material Weakness in Internal Control Over Compliance – Controls over Transfers and Procurement Federal Agency: Department of the Treasury Federal Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Compliance Requirement: A/B – Allowable Costs/Cost Principles I – Procurement and Suspension & Debarment Criteria: Under 2 CFR §200.303, non-federal entities must establish and maintain effective internal control over federal awards to ensure compliance with federal statutes, regulations, and the award terms. • For Allowable Costs: Transfers of CSLFRF funds to support general government services must be supported by documentation demonstrating allowability, compliance, and proper review. • For Procurement and Suspension & Debarment: Per 2 CFR §§200.318–200.326 and 2 CFR §200.213, entities must follow applicable procurement procedures, including state and local bid laws, and must verify that vendors are not suspended or debarred from federal programs. Condition: Transfers made to cover general government services were not supported by documentation of a formal review or approval process. The City did not maintain evidence of procedures to verify the appropriateness or compliance of these transfers prior to execution. In addition, for procurements related to expenditures charged to CSLFRF, the City did not maintain documentation evidencing a review to ensure compliance with state bid law or verification that vendors were not suspended or debarred prior to award. Cause: The City has not implemented formal internal control procedures to document the review and approval of CSLFRF transfers used for general government services and procurement compliance checks, including bid law requirements and vendor suspension/debarment status. These gaps appear to result from limited staffing and/or a lack of awareness of specific federal documentation requirements. Effect: Without documented review and approval, there is an increased risk that CSLFRF transfers may not comply with federal requirements, leading to potential unallowable costs or questioned expenditures, and procurements may not comply with federal or state requirements, increasing the risk of awarding contracts to ineligible vendors or violating competitive procurement rules. The lack of documentation also impairs auditability and transparency in the use of federal funds. Perspective: These issues were identified during audit procedures and are considered systemic, as they affect multiple transactions and compliance requirements. These conditions reflect a lack of formal internal controls over key compliance areas. Questioned Costs: None noted. Recommendation: We recommend that the City implement formal written procedures to strengthen internal controls in the following areas: • Transfers: Require documented review and approval of all transfers, including evidence of management review, verification of eligibility, and compliance with federal guidelines. • Procurement: Require and maintain documentation of procurement reviews, including verification that proper bid laws were followed and confirmation that vendors are not suspended or debarred prior to contract award. View of Responsible Official: See corrective action plan.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
Finding 2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance) Material Weakness – 93.U01 Title V Criteria: Per Uniform Guidance 2 CFR § 200.302 and 2 CFR § 200.333, entities must maintain records that adequately identify the source and application of federal funds and retain documentation to support compliance with program requirements. Additionally, per 2 CFR § 200.213, entities must verify that vendors and contractors receiving federal funds are not suspended or debarred by checking the System for Award Management (SAM) or obtaining vendor certifications. Condition: The Organization was unable to provide sufficient documentation to support compliance with federal procurement and suspension and debarment requirements for purchases made under the Title V program. The general ledger did not allow for sufficient identification of transactions related to the Title V program as all expenditures were recorded through journal entries without supporting transaction-level detail. Due to this limitation, we were unable to select procurement transactions for testing or verify whether vendors had been screened for suspension and debarment before contracts were awarded. Questioned Costs: Unable to determine due to scope limitation. Cause: The Organization did not maintain adequate financial records or procurement documentation to demonstrate compliance with Uniform Guidance requirements. The lack of a complete and detailed general ledger further limited the ability to track and substantiate transactions. Finding 2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance), continued Effect: Without sufficient documentation, the Organization was unable to demonstrate compliance with federal procurement regulations, increasing the risk of noncompliance and potential disallowed costs. Additionally, these expenditures may be subject to repayment or further review by the granting agency. Recommendation: We recommend the Organization strengthen its financial recordkeeping and procurement processes by implementing procedures to ensure a complete and accurate general ledger is maintained. This should include appropriate coding to identify federal program expenditures. The Organization should also establish and enforce procurement policies that align with Uniform Guidance, including documentation of procurement methods, price or cost analyses, and vendor selection, implementing a process to verify and document vendor suspension and debarment status before awarding federally funded contracts, and conducting periodic internal reviews to ensure compliance with procurement and recordkeeping requirements. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance) Material Weakness – 93.U01 Title V Criteria: Per Uniform Guidance 2 CFR § 200.302 and 2 CFR § 200.333, entities must maintain records that adequately identify the source and application of federal funds and retain documentation to support compliance with program requirements. Additionally, per 2 CFR § 200.213, entities must verify that vendors and contractors receiving federal funds are not suspended or debarred by checking the System for Award Management (SAM) or obtaining vendor certifications. Condition: The Organization was unable to provide sufficient documentation to support compliance with federal procurement and suspension and debarment requirements for purchases made under the Title V program. The general ledger did not allow for sufficient identification of transactions related to the Title V program as all expenditures were recorded through journal entries without supporting transaction-level detail. Due to this limitation, we were unable to select procurement transactions for testing or verify whether vendors had been screened for suspension and debarment before contracts were awarded. Questioned Costs: Unable to determine due to scope limitation. Cause: The Organization did not maintain adequate financial records or procurement documentation to demonstrate compliance with Uniform Guidance requirements. The lack of a complete and detailed general ledger further limited the ability to track and substantiate transactions. Finding 2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance), continued Effect: Without sufficient documentation, the Organization was unable to demonstrate compliance with federal procurement regulations, increasing the risk of noncompliance and potential disallowed costs. Additionally, these expenditures may be subject to repayment or further review by the granting agency. Recommendation: We recommend the Organization strengthen its financial recordkeeping and procurement processes by implementing procedures to ensure a complete and accurate general ledger is maintained. This should include appropriate coding to identify federal program expenditures. The Organization should also establish and enforce procurement policies that align with Uniform Guidance, including documentation of procurement methods, price or cost analyses, and vendor selection, implementing a process to verify and document vendor suspension and debarment status before awarding federally funded contracts, and conducting periodic internal reviews to ensure compliance with procurement and recordkeeping requirements. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
Finding 2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance) Material Weakness – 93.U01 Title V Criteria: Per Uniform Guidance 2 CFR § 200.302 and 2 CFR § 200.333, entities must maintain records that adequately identify the source and application of federal funds and retain documentation to support compliance with program requirements. Additionally, per 2 CFR § 200.213, entities must verify that vendors and contractors receiving federal funds are not suspended or debarred by checking the System for Award Management (SAM) or obtaining vendor certifications. Condition: The Organization was unable to provide sufficient documentation to support compliance with federal procurement and suspension and debarment requirements for purchases made under the Title V program. The general ledger did not allow for sufficient identification of transactions related to the Title V program as all expenditures were recorded through journal entries without supporting transaction-level detail. Due to this limitation, we were unable to select procurement transactions for testing or verify whether vendors had been screened for suspension and debarment before contracts were awarded. Questioned Costs: Unable to determine due to scope limitation. Cause: The Organization did not maintain adequate financial records or procurement documentation to demonstrate compliance with Uniform Guidance requirements. The lack of a complete and detailed general ledger further limited the ability to track and substantiate transactions. Finding 2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance), continued Effect: Without sufficient documentation, the Organization was unable to demonstrate compliance with federal procurement regulations, increasing the risk of noncompliance and potential disallowed costs. Additionally, these expenditures may be subject to repayment or further review by the granting agency. Recommendation: We recommend the Organization strengthen its financial recordkeeping and procurement processes by implementing procedures to ensure a complete and accurate general ledger is maintained. This should include appropriate coding to identify federal program expenditures. The Organization should also establish and enforce procurement policies that align with Uniform Guidance, including documentation of procurement methods, price or cost analyses, and vendor selection, implementing a process to verify and document vendor suspension and debarment status before awarding federally funded contracts, and conducting periodic internal reviews to ensure compliance with procurement and recordkeeping requirements. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance) Material Weakness – 93.U01 Title V Criteria: Per Uniform Guidance 2 CFR § 200.302 and 2 CFR § 200.333, entities must maintain records that adequately identify the source and application of federal funds and retain documentation to support compliance with program requirements. Additionally, per 2 CFR § 200.213, entities must verify that vendors and contractors receiving federal funds are not suspended or debarred by checking the System for Award Management (SAM) or obtaining vendor certifications. Condition: The Organization was unable to provide sufficient documentation to support compliance with federal procurement and suspension and debarment requirements for purchases made under the Title V program. The general ledger did not allow for sufficient identification of transactions related to the Title V program as all expenditures were recorded through journal entries without supporting transaction-level detail. Due to this limitation, we were unable to select procurement transactions for testing or verify whether vendors had been screened for suspension and debarment before contracts were awarded. Questioned Costs: Unable to determine due to scope limitation. Cause: The Organization did not maintain adequate financial records or procurement documentation to demonstrate compliance with Uniform Guidance requirements. The lack of a complete and detailed general ledger further limited the ability to track and substantiate transactions. Finding 2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance), continued Effect: Without sufficient documentation, the Organization was unable to demonstrate compliance with federal procurement regulations, increasing the risk of noncompliance and potential disallowed costs. Additionally, these expenditures may be subject to repayment or further review by the granting agency. Recommendation: We recommend the Organization strengthen its financial recordkeeping and procurement processes by implementing procedures to ensure a complete and accurate general ledger is maintained. This should include appropriate coding to identify federal program expenditures. The Organization should also establish and enforce procurement policies that align with Uniform Guidance, including documentation of procurement methods, price or cost analyses, and vendor selection, implementing a process to verify and document vendor suspension and debarment status before awarding federally funded contracts, and conducting periodic internal reviews to ensure compliance with procurement and recordkeeping requirements. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Criteria: Under 2 CFR ?200.318, a non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards. Furthermore, ?200.213 states non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition: During audit procedures performed, we noted that the Chamber does not have a specific policy on procurement or suspension and debarment, and does not have procedures in place to ensure that it complies with federal procurement requirements. Questioned Costs: Unknown Context: The Chamber lacks specific policies on procurement or suspension and debarment, and does not have procedures in place to ensure compliance with federal procurement requirements. Cause: The Chamber was unaware of the policy requirements as this is the first single audit the Chamber has been through in addition to the speed in which the funds were spent due to COVID-19 and the emergency it created for businesses in the area. Effect: Failure of the Chamber to comply with the audit requirements may constitute a violation of the contract and may result in the withholding of future payments. Recommendation: We recommend that the Chamber adopt a procurement and suspension and debarment policy that is in accordance with the requirements established by the Uniform Guidance. Furthermore, we recommend that these policies are approved by the board of directors. Views of responsible officials: There is no disagreement with the audit finding.
Criteria: Under 2 CFR ?200.318, a non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards. Furthermore, ?200.213 states non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition: During audit procedures performed, we noted that the Chamber does not have a specific policy on procurement or suspension and debarment, and does not have procedures in place to ensure that it complies with federal procurement requirements. Questioned Costs: Unknown Context: The Chamber lacks specific policies on procurement or suspension and debarment, and does not have procedures in place to ensure compliance with federal procurement requirements. Cause: The Chamber was unaware of the policy requirements as this is the first single audit the Chamber has been through in addition to the speed in which the funds were spent due to COVID-19 and the emergency it created for businesses in the area. Effect: Failure of the Chamber to comply with the audit requirements may constitute a violation of the contract and may result in the withholding of future payments. Recommendation: We recommend that the Chamber adopt a procurement and suspension and debarment policy that is in accordance with the requirements established by the Uniform Guidance. Furthermore, we recommend that these policies are approved by the board of directors. Views of responsible officials: There is no disagreement with the audit finding.
Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: USDA School Breakfast Program and National School Lunch Program FAL Number: 10.553 and 10.555 Passthrough: New Mexico Public Education Department Award Year: 2022 Criteria: §200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, sub awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. §200.317 Procurements by states. When procuring property and services under a Federal award, a state must follow the same policies and procedures it uses for procurements from its non-Federal funds. The state will comply with §200.322 Procurement of recovered materials and ensure that every purchase order or other contract includes any clauses required by section §200.326 Contract provisions. All other non-Federal entities, including sub recipients of a state, will follow §200.318 General procurement standards through 200.326 Contract provisions. §200.318 General procurement standards. (a) The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. APPENDIX II TO PART 200—CONTRACT PROVISIONS FOR NON-FEDERAL ENTITY CONTRACTS UNDER FEDERAL AWARDS In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. (H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the government-wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” https://www.sam.gov/portal/public/SAM/ SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: During our testing of single audit disbursements, we identified five vendors which would meet the requirement of verifying that the vendor was not suspended or debarred or otherwise excluded from receiving the contract which was funded through Federal dollars. The vendor received single payments in excess of $25,000 from the District from Federal grant sources. The vendors are not currently suspended or debarred from receiving Federal contracts; however, the District did not have proper internal controls in place to verify this prior to the purchase. Questioned Costs: None Cause: District personnel did not verify that vendors which meet the $25,000 thresholds are not suspended, debarred, or otherwise excluded from participating in contracts funded through Federal awards due to a misunderstanding of staff personnel regarding this requirement. Effect: The District is not in compliance with Federal regulations related to the grant and could put funding in jeopardy or require the District to reimburse the program for improper grant distributions.Auditor’s Recommendation: We recommend the District establish a policy and implement procedures regarding large purchases related to Federal grants to insure that no vendors who are suspended, debarred, or otherwise excluded from participating in transactions funded through Federal grants are used. As identified above, there are several methods in which the District can verify vendors are not suspended or debarred. The District may have the vendor provide an annual certification that it is not currently suspended, debarred, or otherwise prevented from receiving Federal dollars. In other occasions in which a single purchase is going to be made, the purchasing procedures should include looking up the vendor on the GSA website, printing a copy of the verification, and placing it in the file with the purchase order. The District has options, and it should establish what method is the least intrusive but also effective in complying with the requirements of the Uniform Grant Guidance. Responsible Official’s Plan: • Specific corrective action plan for finding: The Grants Finance Department, Purchasing Department along with the Federal Grants Department will review vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached. At initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document from SAM.GOV verifying eligibility of vendor will be attached to the vendor file. • Timeline for completion of corrective action plan: July 1, 2023 • Employee position(s) responsible for meeting the timeline: Grants Specialists, CPO, Finance Specialist, Purchasing Specialist, Federal Grants Coordinator, Federal Grants Specialist
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: No Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities. Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the ?Excluded Entity? filter on the ?Exclusions? search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select ?Search? from the header menu from any page on SAM.gov 2) In the filters, under ?Select Domain?, select ?Entity Information?, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Kristin Chotkowski, Purchasing Agent Deadline for Completion: On or before 4/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 1/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 2/1/23.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: No Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities. Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the ?Excluded Entity? filter on the ?Exclusions? search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select ?Search? from the header menu from any page on SAM.gov 2) In the filters, under ?Select Domain?, select ?Entity Information?, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Kristin Chotkowski, Purchasing Agent Deadline for Completion: On or before 4/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 1/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 2/1/23.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: No Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities. Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the ?Excluded Entity? filter on the ?Exclusions? search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select ?Search? from the header menu from any page on SAM.gov 2) In the filters, under ?Select Domain?, select ?Entity Information?, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Kristin Chotkowski, Purchasing Agent Deadline for Completion: On or before 4/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 1/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 2/1/23.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: No Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities. Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 10.553 and 10.555) passed through the New York State Education Department. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the ?Excluded Entity? filter on the ?Exclusions? search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select ?Search? from the header menu from any page on SAM.gov 2) In the filters, under ?Select Domain?, select ?Entity Information?, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Kristin Chotkowski, Purchasing Agent Deadline for Completion: On or before 4/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 1/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 2/1/23.
2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-006 Child Nutrition Cluster ? Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program, School Breakfast Program and Food Distribution Federal Assistance Listing No. 10.555 and 10.553) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District?s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The Interim Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.
2022-006 Child Nutrition Cluster ? Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program, School Breakfast Program and Food Distribution Federal Assistance Listing No. 10.555 and 10.553) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District?s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The Interim Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.
2022-006 Child Nutrition Cluster ? Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program, School Breakfast Program and Food Distribution Federal Assistance Listing No. 10.555 and 10.553) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District?s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The Interim Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.
2022-006 Child Nutrition Cluster ? Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program, School Breakfast Program and Food Distribution Federal Assistance Listing No. 10.555 and 10.553) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District?s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The Interim Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.
Emergency Connectivity Fund Program - Procurement, Suspension and Debarment Information on Federal Program: Federal Communications Commission Emergency Connectivity Fund Program Assistance Listing No. 32.009. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in this specific Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213 for this major program.Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Cost: None. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the major program that were selected for testing, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in all Federal assistance programs or activities is performed prior to disbursing federal funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: Effective immediately, the District is implementing the following: ? The Procurement Specialist in the Technology Department (Maura O?Brien) will check the SAMS Debarment and Suspension website quarterly. ? The data obtained from the quarterly check will be logged into a Google Sheet that is shared with Erin Sheevers, the Chief Technology Officer. ? Any ineligible vendor information will be shared with the Accountant (Steven Terry) in the Business Office. Implementation Date: October 14, 2022.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: YesRecommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The district has entered into an agreement with Capital Region BOCES for the management of our school nutrition department. They will provide documentation that the requirements of 2 CFR Section 200.213 are met and share that information with the district. This will be overseen by the food service director, Todd Barker. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: YesRecommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The district has entered into an agreement with Capital Region BOCES for the management of our school nutrition department. They will provide documentation that the requirements of 2 CFR Section 200.213 are met and share that information with the district. This will be overseen by the food service director, Todd Barker. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: YesRecommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The district has entered into an agreement with Capital Region BOCES for the management of our school nutrition department. They will provide documentation that the requirements of 2 CFR Section 200.213 are met and share that information with the district. This will be overseen by the food service director, Todd Barker. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, and COVD-19 Summer School Food Service Program CFDA No. 10.555, and 10.559) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: YesRecommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The district has entered into an agreement with Capital Region BOCES for the management of our school nutrition department. They will provide documentation that the requirements of 2 CFR Section 200.213 are met and share that information with the district. This will be overseen by the food service director, Todd Barker. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities.