Reporting a determination that an applicant is not qualified for a Federal award.
Agency U.S. Department of Transportation, Federal Motor Carrier Safety Administration ALN 20.232 Commercial Driver’s License Program Implementation Federal Award Identification Number 69A3601840118CDL0NV 69A3601940354CDL0NV 69A3602040472CDL0NV 69A3602140719CDL0NV 69A3602240864CDL0NV Criteria According to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 200.213, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. The non-federal entity must verify that the contractor or subrecipient is not suspended or debarred through the System for Award Management (SAM), which includes reviewing the Excluded Parties List System (EPLS), or by collecting a certification from the entity. Condition and Context The College failed to perform the required search for suspension and debarment in SAM for one of the two contractors tested prior to awarding a contract under the federal program. The search should have been performed to ensure that the contractor was not suspended or debarred. Cause The one vendor noted was a long standing contractor for multiple years with the College and the College made the determination that this requirement was not applicable when these services were being contracted to be renewed. Repeat Finding No Recommendation We recommend that the College implement and adhere to a strict protocol for verifying suspension and debarment status prior to awarding any contracts or subawards under federal programs. This protocol should include performing searches in SAM, documenting the results of the searches, and maintaining evidence of compliance. Views of Responsible Officials and Planned Corrective Action: See attached corrective action plan Questioned Costs None
Finding 2023-002 – Procurement, Suspension and Debarment (Material Weakness in Internal Controls over Compliance and Material Noncompliance) Major Program Affected – AL Number Program Name Award Number Award Year 93.441 Indian Self-Determination 248-96-0027 2023 Criteria – The Tribe’s procurement policies and procedures require at least three written bids or quotes for purchases over $2,500. Federal regulations require that grantees have controls in place to verify that vendors are not suspended or debarred prior to entering into contracts for goods or services exceeding $25,000. In accordance with 2 CFR 200.213, federal regulations and criteria of the Indian Self-Determination and Education Assistance Act (ISDEAA) requires that full bid and open competition be promoted in soliciting offers and awarding contracts for purchases. Contracting without providing for full and open competition is only permitted if there is only one responsible source and no other supplies or services will satisfy agency requirements, among other circumstances. Condition and Context – During the year, the Tribe had eight vendor contracts for the Indian Self-Determination program with expenditures greater than $2,500. Using a random sample methodology, we selected a sample of two vendors. For both vendors tested, we noted there was no evidence that three written bids or quotes were obtained prior to vendor selection. The Tribe provided sole source justification, however, the description for justifying limiting competition was not in accordance with the Tribe’s procurement policy. The Tribe had two vendor contracts with expenditures greater than $25,000. For both vendors tested, we noted there was no evidence that a suspension and debarment check was performed before entering into contracts or making payments to the vendors. Based on our verification on www.sam.gov, we noted both vendors were not suspended or debarred. Cause – A combination of lack of adequate personnel, and insufficient internal controls over the procurement, suspension and debarment procedures may have contributed to this finding. Additionally, the Tribe’s procurement policies do not address the suspension and debarment requirements. Effect – The Tribe could be subjected to questioned costs or other sanctions from funding agencies if they determine the program did not follow its procurement policies. The Tribe could be subjected to questioned costs or other sanctions from funding agencies if they determine vendors paid with federal funding were suspended or debarred. Questioned Costs – We are unable to determine if the Tribe could have obtained a better price for procurement that was not made through a full and open competitive process, and as such we cannot determine if any overpayment may have occurred. Therefore, questioned costs are unknown. Further, the vendors we tested were not suspended or debarred, so there are no question costs to report related to suspension and debarment requirements. Recommendation – We recommend the Tribe re-evaluate its internal controls over procurement, suspension and debarment and implement a supervisory review process to ensure compliance with the Tribe’s policies. We also recommend the Tribe consider updating its procurement policy in accordance with the 2024 Revisions to the Uniform Guidance (2 CFR 200), which would reduce undue burden on the Tribe’s finance and program manager personnel and Tribal Council. Views of Responsible Officials – The Tribe has continued to train new program and department staff regarding procurement thresholds for Request for Proposal’s (RFP’s) and will update the continued training with emphasis on threshold amounts to endure adherence to the current procurement policy. The Tribe has experienced a large amount of program and department personnel turned over post pandemic resulting in program staff that were only minimally trained. The Tribe will complete a comprehensive review of the RFP process and purpose changes to our internal policy and controls to align in the future with guidance standards. The Tribe will implement a two-part process to review bidding procedures to ensure alignment with existing policies. The Tribe has implemented a new debarment procedure that uses time and date stamp information on all debarment searches and an of attestation of search being done and by whom.
Finding 2023-007: Suspension and Debarment Information on the Federal Program: 97.024 - Emergency Food and Shelter National Board Program Type of Finding: Material Weakness in Internal Control over Compliance and Material NoncomplianceCriteria: 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: During our testing over Suspension and Debarment, we determined that SAMU either did not perform screenings, or did not document the screening date on potential or current vendors, suppliers, contractors or employees that were paid with Federal funds. Cause: SAMU does not have a formal internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment. Effect or Potential Effect: Failure to screen, in a timely manner (before contract date or payment occurs) potential and current vendors, suppliers, contractors and 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: $24,000 Context: Out of 4 samples selected for testing, we noted the following: 2 samples did not have evidence of the date of the SAM check being performed; 1 sample had a SAM check date performed after execution of the contract with the vendor; 1 sample did not have a SAM check performed at all. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: 2022-007 Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. All screenings should be conducted prior to entering into an agreement with a vendor. Additionally, evidence of documentation should include the date of when the SAM check was performed. We recommend that SAMU notify all employees of this policy and ensure that it is enforced during the upcoming year.
Coronavirus State and Local Fiscal Recovery Funds Information on Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027. 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 Town is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The Town did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The Town is not in compliance with 2 CFR Section 200.213. The Town 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. 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 Town’s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs or activities. Recommendation: we recommend that the Town 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 responsible officials and Planned Corrective Actions: Moving forward, the Town of Guilderland will ensure that vendors are not included on the suspended or debarred list to ensure compliance with the requirements noted above.
2023-002 Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: U.S. Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance for Africa Grant Award Number: Direct Award Number Award Period SPRMCO23CA0016 November 21, 2022 through July 31, 2024 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 one procurement sample out of a total of six procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. 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 the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS country office personnel did not adhere to CRS’s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a 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 a repeat of finding 2022-003. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. Views of Responsible Officials: Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 24,513 (unaudited) in FY 2023 alone. While management agrees with BDO's assessment of the samples, it should be noted that CRS is strongly committed to compliance with applicable suspension and debarment regulations. Please see Appendix B for Management’s Corrective Action Plan.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
2023-002 Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: U.S. Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance for Africa Grant Award Number: Direct Award Number Award Period SPRMCO23CA0016 November 21, 2022 through July 31, 2024 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 one procurement sample out of a total of six procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. 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 the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS country office personnel did not adhere to CRS’s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a 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 a repeat of finding 2022-003. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. Views of Responsible Officials: Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 24,513 (unaudited) in FY 2023 alone. While management agrees with BDO's assessment of the samples, it should be noted that CRS is strongly committed to compliance with applicable suspension and debarment regulations. Please see Appendix B for Management’s Corrective Action Plan.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.
Finding 2023 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance) (Repeat Finding: 2021-004 and 2022-004) 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. 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.
Significant Deficiency 2023-001 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, 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: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency 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. procedure due to the turnover in the purchasing agent position verification could not be located. 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): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 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, 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: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency 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. procedure due to the turnover in the purchasing agent position verification could not be located. 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): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 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, 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: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency 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. procedure due to the turnover in the purchasing agent position verification could not be located. 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): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
Significant Deficiency 2023-001 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, 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: Yes. Perspective Information: As part of follow up on this prior audit finding requested support for the performance of this Significant Deficiency 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. procedure due to the turnover in the purchasing agent position verification could not be located. 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): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.
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: 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 District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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: 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 District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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: 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 District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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: 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 District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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: 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 District is in a contract with Capital Region BOCES for the management of the school nutrition department. There were staff changes during the year and the new hire was unaware of the requirements. Cathy Meher, District Treasurer will meet with both the new Director and his supervisor at BOCES to relay the audit finding and develop a plan moving forward. This will happen immediately. 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 - Procurement Information on Federal Program: Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, Summer Food Service Program for Children, and Food Distribution (Assistance Listing No. 10.553, Assistance Listing No. 10.555 and Assistance Listing No. 10.559) passed through New York State Education Department. 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. Condition: During our testing, we noted that the District is not documenting the annual verification of the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Cause: The District did not maintain documentation as to the consideration and annual review of a vendor’s eligibility to participate in Federal assistance programs. Effect: The District is not in compliance with 2 CFR Section 200.213. As a result vendors that are not eligible for participation in Federal assistance programs or activities could be paid with federal dollars or the District could be overpaying for goods and services. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that an annual review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to engaging in and disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review and update procedures to document this review. Perspective Information: As part of follow-up to finding 2022-002 we noted that the District reviewed vendors charged to other federal programs but did not verify for the Child Nutrition cluster.
Child Nutrition - Procurement Information on Federal Program: Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, Summer Food Service Program for Children, and Food Distribution (Assistance Listing No. 10.553, Assistance Listing No. 10.555 and Assistance Listing No. 10.559) passed through New York State Education Department. 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. Condition: During our testing, we noted that the District is not documenting the annual verification of the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Cause: The District did not maintain documentation as to the consideration and annual review of a vendor’s eligibility to participate in Federal assistance programs. Effect: The District is not in compliance with 2 CFR Section 200.213. As a result vendors that are not eligible for participation in Federal assistance programs or activities could be paid with federal dollars or the District could be overpaying for goods and services. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that an annual review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to engaging in and disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review and update procedures to document this review. Perspective Information: As part of follow-up to finding 2022-002 we noted that the District reviewed vendors charged to other federal programs but did not verify for the Child Nutrition cluster.
Child Nutrition - Procurement Information on Federal Program: Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, Summer Food Service Program for Children, and Food Distribution (Assistance Listing No. 10.553, Assistance Listing No. 10.555 and Assistance Listing No. 10.559) passed through New York State Education Department. 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. Condition: During our testing, we noted that the District is not documenting the annual verification of the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Cause: The District did not maintain documentation as to the consideration and annual review of a vendor’s eligibility to participate in Federal assistance programs. Effect: The District is not in compliance with 2 CFR Section 200.213. As a result vendors that are not eligible for participation in Federal assistance programs or activities could be paid with federal dollars or the District could be overpaying for goods and services. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that an annual review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to engaging in and disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review and update procedures to document this review. Perspective Information: As part of follow-up to finding 2022-002 we noted that the District reviewed vendors charged to other federal programs but did not verify for the Child Nutrition cluster.
Child Nutrition - Procurement Information on Federal Program: Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, Summer Food Service Program for Children, and Food Distribution (Assistance Listing No. 10.553, Assistance Listing No. 10.555 and Assistance Listing No. 10.559) passed through New York State Education Department. 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. Condition: During our testing, we noted that the District is not documenting the annual verification of the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Cause: The District did not maintain documentation as to the consideration and annual review of a vendor’s eligibility to participate in Federal assistance programs. Effect: The District is not in compliance with 2 CFR Section 200.213. As a result vendors that are not eligible for participation in Federal assistance programs or activities could be paid with federal dollars or the District could be overpaying for goods and services. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that an annual review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to engaging in and disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review and update procedures to document this review. Perspective Information: As part of follow-up to finding 2022-002 we noted that the District reviewed vendors charged to other federal programs but did not verify for the Child Nutrition cluster.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: 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 certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. 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 nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to 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: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: 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 certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. 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 nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to 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: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: 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 certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. 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 nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to 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: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: 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 certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. 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 nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to 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: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Agency for International Development Federal Program Name: Collaboration for African Biodiversity (ABCG III) Assistance Listing Number: 98.001 Federal Award Identification Number and Year: 7200AA20FA0032 - 2023 Pass-Through Agency: World Resources Institute Pass-Through Number(s): FAA-7200AA20FA0032 Award Period: October 1, 2020 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: 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 certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction. 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 nonfederal entity obtains an exception under §180.135. Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence showing that the suspension and debarment verification occurred before the transaction with the vendor was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not suspended or debarred. Questioned costs: None Context: This is a condition based on testing of AWF's compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and procurement procedures outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to 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: No Recommendation: We recommend management to ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: There is no disagreement with the audit finding.
2023-006 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) 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 on an annual basis. They are however, checking the status of any new vendors. 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 District will monitor vendors to ensure they are able to accept federal monies.