Assistance Listing Number, Federal Agency, and Program Name - 10.727, U.S. Department of Agriculture, Inflation Reduction Act Urban & Community Forestry Program Federal Award Identification Number and Year - 24 DG 11094200 194, 2024; 24 CA 11132544 013, 2024 Pass through Entity - U.S. Department of Agriculture (Direct Funded); GreenLatinos Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States, or the Internal Control-Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - Management did not have controls in place to ensure documentation evidencing the organization's verification that contractors are not suspended or debarred from participating in a federally funded activity was maintained. Questioned Costs - N/A If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - While gaining an understanding of Openlands' internal controls, we noted management was unable to provide documentation to support that checks for suspension and debarment occurred before the organization entered into a covered transaction. We were able to verify in our sample testing that management did not enter into contracts with individuals or organizations suspended or debarred from participating in federal programs. Cause and Effect - A lack of controls could result in material noncompliance with federal procurement standards. Recommendation - We recommend management retain documented evidence that checks for suspension and debarment that have occurred before entering into a covered transaction with outside contractors. Views of Responsible Officials and Corrective Action Plan - Management concurs with the finding. We acknowledge that, for the awards issued under the Inflation Reduction Act Urban and Community Forestry Program (Assistance Listing Number 10.727), the required suspension and debarment verification was performed; however, the supporting documentation evidencing this verification was not retained by the responsible department. This represents a documentation lapse rather than a deficiency in internal controls, as Openlands routinely performs suspension and debarment verifications for all applicable vendors, contractors, and subrecipients receiving federal funds in accordance with 2 CFR 200.214. This requirement applies to entities and individuals awarded federally funded contracts or subawards exceeding the micropurchase threshold and excludes routine commercial vendors for indirect administrative costs or purchases under $15,000. Management believes this was an isolated documentation lapse prior to the current audit period when the contractor was selected and is currently in the process of executing an update to internal control policies to ensure these checks are maintained prior to entering into a contract by the responsible department, as well as updating a clause to all standard vendor contracts requiring a self-certification that they are not excluded, debarred, or suspended from entering into covered transactions with the federal government.
2025-001: PROCUREMENT (repeat comment) Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.696 Certified Community Behavioral Health Clinics Expansion (CCBHC) Grants Criteria: Per 2 CFR section 200.214 and section 180.300; 48 CFR section 52.209-6, when entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified. Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Contracts for FY 2025 were the same contracts for FY 2024 for this program. Therefore, this finding is a carryover of the FY 2024 finding. Cause/Effect: Management oversight. Questioned Cost: None Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.
Procurement and Suspension and Debarment Federal Agency: U.S. Environmental Protection Agency Federal Program Title: Drinking Water State Revolving Fund (DWSRF) ALN: 66.468 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2521902915 September 1, 2024 - August 31, 2025 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: "Per 2 CFR §200.303(a), Texas Commission on Environmental Quality (TCEQ) must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR §200.318, the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. Per 2 CFR §200.214, recipients and subrecipients are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition: Audit procedures included a review of five procurements conducted during the fiscal year to assess whether TCEQ adhered to required procurement procedures and performed vendor eligibility verifications prior to entering into covered transactions. For one procurement, totaling $16,175, the required procurement processes were not followed, and the necessary vendor compliance checks, including verification of suspension and debarment status, were not completed before executing the transaction. Questioned costs: None. Context: See “Condition.” Cause: The procurement was initiated directly by the program area without notifying or coordinating with the Procurement and Contracts Section. Program staff proceeded with the purchase under the assumption that procurement involvement was unnecessary because the selected vendor was the sole provider of the required item. As a result, established procurement procedures and vendor compliance verification processes were not followed. Effect: Failure to follow procurement procedures and complete proper vendor compliance checks prior to entering into a covered transaction may lead to entering contracts with suspended or debarred vendors that could result in noncompliance and questioned costs. Repeat Finding: No Recommendation: TCEQ should provide targeted training to program staff on federal procurement requirements, including the necessity of coordinating all purchases through the P&C Section and completing required vendor compliance checks. Training should emphasize procedures for sole‑source or limited‑source procurements and reinforce staff responsibilities under 2 CFR procurement and internal control standards. Regular refresher sessions and documented guidance will help ensure consistent understanding and adherence to required procurement practices across all program areas. Views of responsible officials: The Financial Administration Division (FAD) will implement the audit’s recommendations. FAD will reinforce the guidance provided through continuous training, documentation, and improved internal controls.
FINDING 2025-001 SUSPENSION AND DEBARMENT SIGNIFICANT DEFICIENCY Federal Program: Charter Schools Program Assistance Listing Number: 84.282A Criteria 2 CFR 200.214 states that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition The School does not have a policy in place outlining the process to check that vendors are not suspended or debarred. Additionally, the School could not support that these checks were being completed for vendors paid using federal program funds. Cause The School was not aware of the requirement to check vendors for suspension and debarment. Effect Failing to check vendors for suspension and debarment could result in improperly paying vendors with funds from federal sources. Recommendation We recommend the School develop a policy and internal controls to ensure vendors paid with federal funds are checked for suspension or debarment. Views of Responsible Officials The School’s Corrective Action Plan is included on page 26.
Child Nutrition Cluster - Procurement - Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Commodities, Summer Food Service Program Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of the District’s vendors charged to the fund, and none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 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. This should be verified on an annual basis. Views of responsible officials and planned corrective actions: The District will review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 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. This will be verified on an annual basis. Anticipated implementation date is October 1, 2025 by responsible person(s) District Business Official and District Treasurer Kelsey Reed.
Child Nutrition - Procurement - Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, Snack, non-cash commodities, Summer Food Service Program, Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis for the school lunch fund vendors. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of vendors charged to the school lunch fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 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. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: Effective September 15, 2025 the District Treasurer will check the status of all vendors associated to the Child Nutrition program. In cooperation with the Food Service Director, the District Treasurer will review eligibility of any vendors that are requested to be used. Any vendor that is found not to be eligibility list will be reported to the Food Service Director and Purchasing Agent. This list will be updated and checked annually.
Child Nutrition Cluster - Procurement. Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, non-cash assistance, Summer Food Service Program Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District was able to obtain information through the bidding process that the vendor had been reviewed for suspension and debarment, they also ensured the District’s vendors charged to the fund, were not suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 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. This should be verified on an annual basis. Views of Responsible Officials and Planned Corrective Actions: The District acknowledges the finding and agrees with the recommendation. To address this issue the Business Office will verify all vendors used in federally funded programs at least once annually and prior to disbursing funds. Michele Hogan and April Young will be responsible with an anticipated completion date of September 30, 2025. Staff will review both 2 CFR Section 200.214 and 2 CFR Part 180 for understanding and compliance. Michele Hogan and John Lybert will be responsible with an anticipated completion date of September 30, 2025.
Child Nutrition Cluster - Procurement. Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing Numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal assistance programs or activities. Statement of Condition: During our discussions with management, 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 200.314 and 2 CFR Part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. 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. Perspective Information: As part of the requirements under the Uniform Guidance, 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. Questioned Cost: None. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 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 Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed.
Child Nutrition Cluster - Procurement. Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 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 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Child Nutrition program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.314 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. 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 procurement testing, a review of vendors charged to the school lunch fund and therefore represented 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 200.214 and 2 CFR part 180 and ensure that their procurement procedures are being followed and 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 review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure procurement procedures are being followed. Further, the District will perform and document a review of the eligibility of vendors to participate in Federal assistance programs. The District is in the process of corrective action, and is working toward compliance.
Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, noncash assistance, Summer Food Service Program Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. U.S. Department of Education Special Education Cluster (Special Education – Grants to States and Special Education – Preschool Grants Assistance Listing Numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Additionally, we noted that there was no verification that procurements through state contracts were invoiced to the District at the contract rates. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. 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. The District could also be overpaying for goods. Questioned Costs: None Perspective Information: A review of vendors charged to the major programs determined no vendors were suspended or debarred. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 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. This should be verified on an annual basis. Additionally, we recommend that a review of invoices as compared to bidding/contracting documentation be performed prior to payment. Views of responsible officials and planned corrective actions: Effective July 1, 2025 the Executive Director of Business & Human Resources, Kevin J. Polunci will review and and verify the eligibility of vendors that participate in federal assistance programs and on an annual basis. Additionally, the District will review the eligibility of potential vendors that participate in federal assistance programs and compare invoices to bidding/contracts prior to payments.
Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, non-cash commodities, Summer Food Service Program, Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis for all school lunch vendors. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of all vendors charged to the school lunch fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 20.214 and 2 CFR Part 180 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. This should be verified on an annual basis. Views of the Responsible Officials: The District will begin verifying the status of all vendors paid with federal funds to ensure they are not suspended or debarred.
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 Assistance Listing numbers 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 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating 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. In addition, the District does not have any procedures in place to verify purchases against the bidding documents for pricing. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.314 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. 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. The District could also be overpaying for goods as the bid documentation is not being verified against the purchases made. 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. Also as part of the required follow up of prior year audit findings, inquiries were performed to determine if bidding and procurement procedures were being followed, and they were not. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR part 180 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. The District should also implement procedures to verify their purchases against bidding documentation to ensure that they are paying the correct, bid upon price for their purchases. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
2025-003: Procurement Procedures (Significant Deficiency and Noncompliance) Federal Program: IDEA Special Education Federal ALN: 84.027/84.173 Criteria: Under 2 CFR §200.318-§200.320, non-federal entities must conduct all procurement transactions in a manner providing full and open competition and must follow documented procurement procedures consistent with federal standards. Additionally, 2 CFR §200.214 (previously §200.213) requires non-federal entities to verify that contractors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the System for Award Management (SAM.gov) or obtaining a certification from the vendor. Condition and Context: During our testing of procurement transactions, we identified two (2) contracts in which bids were not solicited as required by the District's procurement policy and Uniform Guidance. In addition, suspension and debarment checks were not performed or documented for these vendors prior to contract award. Cause: The exceptions occurred because procurement procedures were not consistently followed, and management did not perform or document required suspension/debarment verifications prior to contract execution. This may have been due to oversight or lack of staff training regarding Uniform Guidance procurement requirements. Effect or Potential Effect: Failure to solicit bids and perform suspension/debarment checks increases the risk of noncompliance with federal regulations, potential ineligible costs charged to federal programs, and diminished assurance that contracts are awarded fairly and to responsible parties. Questioned Costs: None. Identification as a Repeat Finding: No. Recommendation: We recommend that management strengthen procurement procedures to ensure compliance with Uniform Guidance requirements. Specifically: - Solicit bids or proposals in accordance with applicable competitive procurement thresholds; - Perform and document suspension and debarment checks (e.g., through SAM.gov) prior to awarding contracts; and - Provide staff training on federal procurement standards and maintain documentation supporting compliance for each federally funded procurement. Responsible Official's Response: Please see the last page of this report for the response to this finding.
Special Education Cluster – Procurement Information on Federal Program: U.S. Department of Education Special Education Cluster (Special Education – Grants to State (IDEA, Part B) and Special Education – Preschool Grants (IDEA Preschool) Assistance Listing numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the special education cluster and therefore represents 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. The District did perform a retrospective review of all vendors associated with federal grants, and encountered no vendors that were suspended or debarred. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 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. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: Effective September 2025, the District has implemented a procedure to perform this review on vendors associated with federal grants annually.
U.S. Department of Treasury Federal Assistance Listing #21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, & Debarment Material Weakness in Internal Control Over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.318 requires the auditee to use its own documented procurement procedures which reflect State, local and tribal laws and regulations, provided that the procurements conform to applicable Federal law and standards. 2 CFR 200.214 restricts making federal awards with certain parties that are debarred, suspended, or otherwise excluded from participating in Federal awards. Condition: The Hospital did not have a written procurement policy in place that aligned with all federal regulations. The Hospital also did not review vendors to ensure that they were not debarred, suspended, or otherwise excluded from participating in federal awards. Cause: While the Hospital did have a policy in place, the policy did not follow all federal regulations, or include policies of determining if vendors are debarred, suspended, or otherwise excluded from participating in Federal awards. Effect: Noncompliance with the Uniform Guidance could jeopardize future federal funding. Questioned Costs: None reported Context: A nonstatistical sample of 3 vendors out of 9 vendors with actual or anticipated expenditures greater than the federal micro purchase threshold were tested for procurement testing. Repeat Finding from Prior Years: No. Recommendation: The Hospital should update their procurement policy to align with all federal requirements outlined in 2 CFR 200.318. We also recommend that the Hospital reviews vendors that are used for federal awards to ensure that they are not debarred, suspended, or otherwise excluded from participating in Federal awards in accordance with 2 CFR 200.214. Views of Responsible Officials: Management agrees with the finding.
Reference Number: 2025-006 Program Name: Special Education Cluster Description: Procurement, Suspension and Debarment Condition: During our testing of procurement, the District did not retain documentation demonstrating the suspension and debarment status of two (2) vendors paid. While the District verbally stated that SAM.gov checks were performed, no evidence was available for examination. Criteria: 2 CFR 200.214 requires Districts to ensure, and retain evidence, that the verification process was complete. Verification can be documented through 1) a screenshot or printout from SAM.gov, 2) An official certification from the vendor, or 3) a written record the verification was completed. Cause: The District’s procurement policy does not formally state that retention of the search is required. Effect: The District can’t demonstrate compliance with federal procurement requirements. Questioned Costs: None. Identification of a Repeat Finding: This is not a repeat finding. Auditors’ Recommendation: We recommend that the District update their procurement policy to include that retention of the search is required. Views of Responsible Officials: See attachment for District’s corrective action plan.
2025: Procurement Procedures (Significant Deficiency and Noncompliance) Federal Program: American Recovery Plan Act Federal ALN: 21.027 Criteria: Under 2 CFR 200.214 (previously 200.213) requires the City to verify that contractors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the System for Award Management (SAM.gov) or obtaining a certification from the vendor. Condition and Context: During our testing, we identified two (2) transactions for which suspension and debarment checks were not performed or documented prior to contract award. Cause: Undetermined. Effect or Potential Effect: Failure to perform suspension/debarment checks increases the risk of noncompliance with federal regulations, potential ineligible costs changed to federal programs, and diminished assurance that contracts are awards fairly and to responsible parties. Questioned Costs: None. Identification as a Repeat Finding: No. Recommendation: We recommend that management strengthen procurement procedures to ensure compliance with Uniform Guidance requirements. Specifically: - Perform and document suspension and debarment checks (e.g., through SAM.gov) prior to awarding contracts; and - Provide staff training on federal procurement standards and maintain documentation supporting compliance for each federally funded procurement. Responsible Official's Response: Please see the last page of this report for the response to this finding.
2025-002 Special Education Cluster: Suspension and Debarment Federal Agency: United States Department of Education Federal program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024/2025-585264-DPI-FLOW-341, 2024/2025-585264-DPI-PRESCH-347 Award Period: 07/01/2024 – 06/30/2025 Compliance Requirements Affected: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing we noted the District does not have a consistent procedure in place for verifying that vendors are not debarred, suspended, or otherwise excluded. Questioned costs: None Context: In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for two of the four vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Effect: The District could contract with a vendor that has been suspended or debarred from receiving Federal Funds. Repeat Finding: 2024-005 Recommendation: We recommend that the District reviews its procedures to ensure the District’s suspension and debarment policy is being consistently followed. We further recommend that the District requires all grant administrators to receive training on Federal suspension and debarment regulations. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.
Finding: 2025-003 Procurement, Suspension, and Debarment (Significant Deficiency) Federal Agency(ies): United States Department of Agriculture Federal Program(s): Partnerships for Climate-Smart Commodities Assistance Listing Number(s): 10.937 Pass-through Entity (if applicable): N/A Award Identification Number and Year: NR233A750004G045 (2023) Criteria or Specific Requirement: 2 CFR 200.320(a)(1)(iv) allows for an increased micro-purchase threshold of up to $50,000 only if the non-Federal entity self-certifies that it meets specific conditions, including internal controls, organizational risk, and procurement oversight capacity. 2 CFR 200.214 prohibits contracting with or making subawards to parties that are suspended or debarred, and entities are required to verify that contractors are not listed on the System for Award Management (SAM.gov) at the time of contact/award. 2 CFR 200.318(c)(1) requires non-Federal entities to maintain written standards of conduct covering conflicts of interest and governing the performance of employees engaged in the selection, award, and administration of contracts. Condition: Our testing identified the following exceptions: 1. CIF did not maintain a comprehensive written procurement, suspension, and debarment policy during the fiscal year under audit. A draft policy was developed during the audit planning phase and is pending approval from the Board of Directors. 2. The draft policy self-certified a micro-purchase threshold of $50,000, which is not appropriate given that CIF does not meet all criteria required under 2 CFR 200.320(a)(1)(iv), and the elevated threshold is excessive relative to the size and scope of the Organization’s operations. 3. CIF provided SAM.gov suspension and debarment checks for contractors in our sample; however, the checks were undated, and we were unable to confirm that the verification was performed at the time of contract execution. 4. CIF did not maintain a conflict of interest policy during the fiscal year under audit, as required by 2 CFR 200.318(c)(1). While a draft conflict of interest policy was included in the draft procurement policy, it was not in effect during the year under audit. Cause: These conditions occurred because the Organization did not have formalized procurement policies and procedures in place throughout the year. Effect or Potential Effect: Failure to maintain compliant procurement and conflict of interest policies and procedures increases the risk that Federal funds may be spent in a manner inconsistent with Uniform Guidance requirements. Questioned Costs: $172,572 (all contractual expenses changed to ALN #10.937) Context: We tested a statistically valid sample of contractual relationships charged to Federal awards. The deficiencies noted were consistent across the sample population, indicating a systemic issue rather than isolated exceptions. Identification as a Repeat Finding, if Applicable: Yes, repeat of Finding 2024-006Recommendation: We recommend that management: 1. Finalize and implement a comprehensive procurement, suspension, and debarment policy that incorporates all requirements of 2 CFR 200.318–200.320. 2. Amend the draft policy to adopt a micro-purchase threshold appropriate for the Organization’s size and risk profile, consistent with 2 CFR 200.320(a)(1)(iv). 3. Ensure that SAM.gov checks are performed and documented with date-stamps at the time of contract execution. 4. Adopt and enforce a formal conflict of interest policy as required by 2 CFR 200.318(c)(1), and amend the policy to require annual (written) reaffirmations from all employees and Board members.
Criteria: Uniform Guidance (2 CFR §200.214 and §200.318(h)) prohibits non-federal entities from contracting with or making subawards to parties that are suspended or debarred. Entities must verify vendor eligibility by: Checking SAM.gov, Obtaining a vendor certification, or Adding a clause in contracts stating the vendor is not suspended or debarred. Condition: The Town did not have adequate internal controls to ensure compliance with the suspension and debarment requirements of the Uniform Guidance when procuring goods or services using federal funds. Cause: The Town had not established written procedures or implemented controls to ensure required suspension and debarment checks were performed and documented during procurement involving federal funds. Effect: Without controls to ensure compliance with suspension and debarment requirements, the Town is at increased risk of awarding federal funds to ineligible vendors. This could result in unallowable costs, questioned costs, or potential repayment of federal funds. Recommendation: The Town should develop and implement written policies and procedures requiring documentation of suspension and debarment checks before entering into contracts funded with federal awards. Acceptable methods include maintaining SAM.gov eligibility verification screenshots, obtaining vendor certifications, or including appropriate contract language. Views of responsible officials: See management’s responses to findings on Page 78.
74 Section III - Findings and Questioned Costs for Federal Awards (Continued) Significant Deficiency 2025-002 - PROCUREMENT, SUSPENSION & DEBARMENT: Procurement Policy Federal Program Information: US Department of Agriculture Direct Award ALN: - 10.760 Water and Waste Disposal Systems for Rural Communities Criteria: Per 2 CFR Section 200.214, non-federal entities are subject to the nonprocurement and suspension regulations restricting awards, subawards, and contracts with certain parties that are debarred or suspended. Condition: The Town does not have a formal procedure to determine that contractors are not debarred, suspended or otherwise excluded or ineligible for participation in Federal assistance programs or activities. Cause: The Municipality is working on adopting an updated federal procurement policy in response to the prior year finding, but it has not been adopted yet. Effect: Transactions could occur that did not comply with federal regulations. Identification of Questioned Costs: None identified. Context: The finding was based on requesting the Town’s policies and procedures related to federal compliance and therefore was not the result of a statistical sample. Repeat Finding: This is a repeat finding of 2023-003. Recommendation: The auditor recommends that the Town obtain an understanding of the required procedures in the Code of Federal Regulations as applicable to its federal programs, create and formally adopt those required procedures. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Bridgewater, Vermont.
NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30, 2025 Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The city did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The city does not have procurement policies and procedures in place that allows it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
2025-006 Procurement, Suspension & Debarment – Special Education Cluster (IDEA) Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Wisconsin Department of Instruction Pass Through Numbers: 2025-445138-DPI-ES3-342, 2025-445138-DPI-FLOW-341, 2025-445138-DPI-PRESCH-347 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal control over Compliance, Material noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Questioned Costs: None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Context: During our testing of procurement transactions of the program, we noted the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of 3 vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for two vendors. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all four vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement. Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. Additionally, the District could contract with a vendor that has been suspended or debarred from receiving Federal funds. Repeat Finding: No Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials: There is no disagreement with the finding.
2025-001 –Procurement, Suspension and Debarment Cluster / Program: Research & Development (R&D) / ALN 19.UO9, 19.U10: The MITRE Corporation – U.S. Department of State Grantor: - Defense Advanced Research Projects Agency (DARPA) / DoD, National Science Foundation (NSF) / U.S. Department of State Award Name: EE Tang MPI PennST DARPA Monolithic GaN, Social Networks and Migration in Nepal / Conflict Observatory – Sudan, Conflict Observatory – Ukraine Award Number: AWD0011529, AWD0007921 / AWD0011946, AWD0010905 Award Year: FY2025 Assistance Listing Numbers: 12.910, 47.075 / 19.U09, 19.U10 Assistance Listing Titles: Research and Technology Development, Social, Behavioral, and Economic Sciences / U.S Department of State Pass-Through Entities: N/A / Pennsylvania State University Criteria Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the transaction. Condition We selected a sample of 25 transactions within the R&D cluster and 5 transactions within ALN 19.U09, 19.U10 and noted two selections within R&D cluster and one selection within ALN 19.U09, 19.U10 where debarment checks were not performed prior to entering into the transaction. Cause Due to the manual nature of the debarment checks, there was an oversight and the vendors were not screened at the time of set up due to human error. Effect New vendors are not consistently checked for suspension and debarment prior to the University entering into a transaction with the vendors as required by the regulation stated above. Questioned Costs None noted. Repeat Finding in the Prior Year No Recommendation PwC recommends additional training for employees responsible for suspension and debarment checks to ensure established procedures are followed when entering into a covered transaction with an entity. Additionally, we recommend considering an automated process where when a new vendor is entered into the system, a debarment check is automatically initiated.
FINDING 2025-002 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): 21611-010-PN01, 22611-010-PN01, 23611-010-PN01, 24611-010-PN01, 22611-010-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-004. Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., a grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a person with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation did provide documentation that suspension and debarment requirements were verified for one of the tested vendors. No documentation was provided for the remaining covered transactions, totaling $329,876. The lack of proper internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 18 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this 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." 2 CFR 200.214 states: "Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities." Cause A proper system of internal controls was not designed by management of the School Corporation to ensure all vendors to whom payments equal to or in excess of $25,000 were verified prior to entering into subawards and covered transactions. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not all verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provision of federal statutes, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 19 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish and implement an effective system of internal controls to ensure all vendors to whom payments equal to or in excess of $25,000 are verified prior to entering into subawards and covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2025-001 U.S. Department of Education, Assistance Listing #84.027/84.173 Special Education Cluster (IDEA) Program and U.S. Department of Treasury, Assistance Listing #21.027 Coronavirus State and Local Fiscal Recovery Funds (SLRF) Program for the period of July 1, 2024, through June 30, 2025 Criteria: Uniform Guidance section 2 CFR §200.317-200.327 Procurement Standards, requires purchases exceeding the micro-purchase threshold of $10,000 to follow small purchase procedures, which require obtaining price or rate quotations from an adequate number of qualified sources (§200.320) prior to entering into a contract. In addition, 2 CFR Part 180 and 2 CFR §200.214 require non-federal entities to verify if contractors are suspended or debarred (e.g., Sam.gov check or certification) and include appropriate contract clauses in applicable contracts. Condition: The School Department did not obtain price or rate quotations for two projects that exceeded the micro-purchase threshold. Additionally, the Department did not perform, or document required suspension and debarment procedures for the contractor (e.g., verification against SAM.gov, obtaining certifications, or including contract clauses). The City did not perform, or document required suspension and debarment procedures for the contractor (e.g., verification against SAM.gov, obtaining certifications, or including contract clauses) for three of the six contracts tested. Cause: School staff were not aware the projects would be funded with federal funds and did not ensure compliance with federal requirements for competitive pricing and suspension/debarment verification. City staff were not aware projects covered under the SLRF definition of “revenue replacement”, which excludes most procurement requirements, are still required to follow 2 CFR Part 180 and 2 CFR §200.214. Effect: Failure to obtain competitive quotes and verify contractor eligibility to receive Federal funds increases the risk of noncompliance, inefficient use of federal funds, and potential disallowance of costs. Known Questioned Costs: $61,891 for #84.027/84.173; $51,750 for #21.027 Likely Questioned Costs: $12,799 for #21.027 Recommendation: We recommend training staff on procurement and suspension/debarment requirements and implementing a pre-award compliance checklist. We also recommend increasing communication between grant personnel and facilities management personnel so all parties are aware which projects will be funded with federal funds.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - H4HRGP33345 Pass-through Entity - State of Colorado, Department of Local Affairs, for the benefit of the Division of Housing Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - Management did not have controls in place to ensure documentation was maintained evidencing the organization's verfication that contractors are not suspended or debarred from participating in a federally funded activity. Questioned Costs - N/A If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - While gaining an understanding of the organization's internal controls, we noted management was unable to provide documentation to support that checks for suspension and debarment occurred before the organization entered into a covered transaction. We were able to verify in our sample testing that management did not enter into contracts with individuals or organizations suspended or debarred from participating in federal programs. Cause and Effect - A lack of controls could result in material noncompliance with federal procurement standards. Recommendation - We recommend management retain documented evidence that checks for suspension and debarment have occurred before entering into a covered transaction with outside contractors. Views of Responsible Officials and Corrective Action Plan - Management concurs with the finding. We acknowledge that, for one federal program under the Coronavirus State and Local Fiscal Recovery Funds program (Assistance Listing 21.027), the required suspension and debarment verification was performed; however, the supporting documentation evidencing this verification was not retained in the contract file. This represents a documentation lapse rather than a control deficiency. Volunteers of America Colorado (VOAC) routinely performs suspension and debarment verifications for all applicable vendors, contractors, and subrecipients receiving federal funds in accordance with 2 CFR 200.214. This requirement applies to entities and individuals awarded federally funded contracts or subawards exceeding the micro purchase threshold and excludes routine commercial vendors for indirect administrative costs or purchases under $10,000. To strengthen compliance documentation and ensure consistent audit support, VOAC has implemented the following corrective actions: 1.Policy Enhancement: The procurement procedure has been updated to explicitly require saving and retaining a time stamped screenshot or PDF confirmation of each SAM.gov verification showing the verification date and results. Where applicable, contractors subject to 2 CFR 200.214 must also provide a self certification statement within the executed agreement. 2.Centralized Recordkeeping: Verification evidence will be maintained in both the individual contract file and the centralized grant management system. 3.Annual Training and Refresher: Procurement and grants management staff will participate in annual training to reinforce 2 CFR 200.214 requirements and best practices for documentation and record retention. Management believes this was an isolated documentation lapse prior to the current audit period when the contractor was selected, and that the actions taken since have resolved the issue and will ensure continued compliance.
Compliance Requirement: Procurement, Suspension and Debarment Campus:Sacramento Cluster name/program: Supplemental Nutrition Assistance Program Cluster Federal Assistance Listing Numbers: 10.561 Federal Award Identification Number: 21-3068 and 24-3069 Federal Agency: U.S. Department of Agriculture Passed through Entity: State of California Department of Social Services Award Year: July 1, 2024 – June 30, 2025 Criteria: According to 2 CFR 200.214, recipients and subrecipients are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Additionally, 2 CFR 180.300 requires non-federal entities (including state agencies administering federal programs like SNAP) to verify that contractors and subrecipients are not suspended or debarred from receiving federal funds CFR 200.303 also requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: During our testing of 2 procurement samples, it was noted that the program personnel did not check if the vendors were suspended or debarred from receiving federal funds before entering into a covered transaction, nor was a certification from the vendor about verification of suspension and debarment collected from the vendor. We noted the vendors were not suspended or debarred and there were no other exceptions noted in the procurement, suspension and debarment testing. Cause and Effect: The control over the verification that vendors are not suspended or debarred prior to entering into a covered transaction was not designed effectively. As such, the suspension and debarment check requirements were not implemented for all procurement methods for this program. Questioned Costs: None Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No Recommendations: We recommend the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Views of Responsible Officials: The University concurs with the recommendations. The University will review and enhance its procedures and internal controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor.
FINDING 2025-002 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 15 CLOVERDALE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000 per Indiana Code. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases of $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchases were followed. The School Corporation did not obtain price or rate quotes from multiple vendors for its audit period expenditures with each of the three vendors tested in the small purchases category. Documentation detailing the history of procurement, including rationale to limit competition at the time of the expenditure(s) was not provided for audit. Suspension and Debarment Nonfederal entities and contractors are subject to nonprocurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that entity, or adding a clause or condition to the covered transaction with that entity. The School Corporation had not designed or implemented adequate policies or procedures to ensure that applicable vendors who received federal funds over certain thresholds were not suspended or debarred from participating in federal awards programs. There were three vendors subject to suspension and debarment requirements during the audit period that were not procured through the School Corporation's affiliated Educational Services Center for cooperative purchasing. The School Corporation did not perform procedures to ensure the vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities for one of these three vendors. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to small purchases for procurement and one vendor noted for suspension and debarment. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 CLOVERDALE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will 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. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. . . . (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small Purchases– (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 200.214 states: "Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or INDIANA STATE BOARD OF ACCOUNTS 17 CLOVERDALE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed nor implemented an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The Food Service Director indicated that some of these purchases may have been emergency situations but was unaware of the need to document the rationale at the time of the transaction if competition was limited for small purchases procurements. Effect The lack of an internal control system enabled material noncompliance to occur and remain undetected. Noncompliance with the Procurement and Suspension and Debarment compliance requirement could enable small purchases made by the School Corporation to be uncompetitive and could lead to contracting with vendors who are suspended or debarred from receiving federal grant funding. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management strengthen its system of internal controls over small purchase requirements to ensure that an adequate number of price or rate quotes are obtained before purchase. Additionally, if procurements are made in emergency or extenuating circumstances, documentation at the time of the transaction must be retained for audit to justify limiting competition. We also recommended that vendors with a single or aggregate transaction amounts of $25,000 per fiscal year are verified for suspension and debarment prior to entering into the transaction and/or contract. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria or specific requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.214 specifies that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations related to subawards and contracts with certain parties. The non-federal entity must have controls in place to ensure subawards and contracts are not entered into with suspended or debarred parties. Condition: Verification support did not indicate the date verification procedures were performed. As a result, we were unable to verify this was performed prior to engaging with the contractor. Questioned costs: None. Context: Suspension and debarment verification support from SAM.gov did not explicitly state the date the verification procedures were performed. Support was not available to ensure verification procedures were performed prior to the date CAPECO engaged with the contractor. Cause: During the verification process, management failed to include a date stamp for the online print out to support the date the verification procedures were performed. Effect: Suspension and debarment verification support from SAM.gov did not explicitly state the date the verification procedures were performed. Repeat finding: Not a repeat finding. Recommendation: We recommend CAPECO ensure documentation is retained to support the date the suspension and debarment verification procedures are performed. Views of responsible officials: There is no disagreement with the audit finding.
2025-001 – Suspension and Debarment (repeat comment) Finding Type: Significant deficiency in internal control over compliance Program: ALN 97.044 – Assistance to Firefighters Grant • Grant number EMW-2022-FG-01118 • Grant number EMW-2023-FG-03417 • Grant number EMW-2023-FG-02529 Criteria: As required by 2 CFR 200.214, Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition: The vendors used for these grants were not checked for suspension and debarment prior to execution of the contract. Cause/Effect: Although a policy has been adopted requiring a check the suspension and debarment status prior to entering into contracts, the internal control over this process was not operating as designed. Questioned Cost: None. Recommendation: We recommend that the City update procedures to ensure that a check of suspension and debarment status is obtained prior to entering into a covered transaction. View of Responsible Official: Management is in agreement with this recommendation.
Failure to Verify Contractor Suspension and Debarment Status. Condition: The City did not verify the suspension or debarment status of a contractor prior to awarding a federally funded contract during the audit period. Criteria: Federal regulations (2 CFR 200.214) require recipients of federal funds to ensure that contractors are not suspended or debarred prior to awarding a contract. Verification may be documented through a SAM.gov search, a contractor certification, or a contract clause addressing suspension and debarment. Cause: The City's current procurement procedures do not specifically outline how suspension and debarment checks should be performed or documented. Staff were unaware of the requirement. Effect: The City increased the risk of awarding federal funds to a contractor who may be suspended or debarred, which could result in noncompliance with federal regulations and potential disallowance of costs. Questioned Costs: None. Recommendation: We recommend the City update its procurement procedures to include a clear process for verifying and documenting suspension and debarment status for all federally funded contracts. Acceptable documentation includes a printed SAM.gov search, a contractor certification, or a contract clause addressing the requirement. Management Response: Management agrees with the finding. The City will revise its procurement procedures and train staff to ensure verification is completed and retained for all federally funded procurements.
2025-004 Suspension & Debarment – Special Education Cluster (IDEA) Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Wisconsin Department of Instruction Pass Through Numbers: 2025-133675-DPI-FLOW-341, 2025-133675-DPI-PRESCH-347 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Suspension and Debarment Criteria or specific requirement: 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program, we noted that the District did not retain documentation of verification that that vendors are not debarred, suspended or otherwise excluded. Questioned Costs: None Context: In sample of 5 vendors contracts subject to suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all vendors that were selected for testing. Cause: The District did not retain documentation following their Federal Funds Procurement policy related to the appropriate methods of procurement. Effect: The District could contract with a vendor that has been suspended or debarred from receiving Federal funds. Repeat Finding: No Recommendation: We recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials: There is no disagreement with the finding.
Reference Number: 2025-019 Prior Year Finding: 2024-052 Federal Agency: National Science Foundation State Agency: Higher Education Policy Commission Federal Program: Research and Development Cluster Assistance Listing Number: 47.076 Award Number and Year: 1834586 (09/01/2018 – 08/31/2025) Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Compliance: 2 CFR 200.214 Suspension and Debarment restricts 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. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Higher Education Policy Commission (HEPC) did not properly verify and document the suspension and debarment status of subrecipients. Context: Nine transactions were selected for testing, including five for West Virginia University, one for Shepherd University, two for HEPC, and one for the Department of Agriculture. The following exceptions were noted: HEPC: • For 1 of 2 transactions selected for testing, HEPC performed the suspension and debarment verification after the subaward issuance date. The subaward was issued on 10/31/2023 but the suspension and debarment verification occurred on 12/4/2024. • For 1 of 2 transactions selected for testing, HEPC performed a suspension and debarment verification, but it was not dated and auditors were unable to determine if it occurred prior to issuance of the subaward. Questioned costs: None noted. The subrecipients were not suspended or disbarred. Cause: HEPC’s procedures and internal controls were not sufficient to ensure that it performed suspension and debarment verifications prior to issuance of subawards nor that documentation of the verifications was maintained and was complete. Effect: Failure to verify the suspension and debarment status of subrecipients prior to issuance of subawards could result in HEPC entering into agreements with subrecipients who are ineligible to participate in the program. Recommendation: HEPC should review and enhance its controls and procedures to ensure that it verifies the suspension and debarment status of subrecipients prior to issuance of subawards and include documentation for when the check occurred. Views of responsible officials: Management concurs with the finding and has developed a plan to correct the finding.
riteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not documented for four covered transactions. Cause: Procedures were not in place to document that the required suspension and debarment checks were performed at the time of the initial procurement but have since been implemented. Effect: The Town was at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the four vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2024-002 Recommendation: The Town must ensure that there is documentation that all contractors under covered transactions that are performing services for Federal awards are not suspended or debarred. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus Relief Fund Assistance Listing Number: 21.019 Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency over Compliance and Other Matters Criteria or specific requirement: 2 CFR 200.303 requires non-federal entities to establish and maintain internal control designed to reasonably ensure compliance with federal statutes and regulations, including procedures to verify and document vendor eligibility. 2 CFR 200.214 requires verification that vendors are not suspended or debarred prior to entering into covered transactions. Condition: The City does not have a documented control to perform and retain evidence of suspension and debarment verification (e.g., SAM.gov check or vendor certification) at the time of entering into covered transactions funded by federal awards. Management indicated that vendor eligibility checks are performed as part of standard operating practice; however, documentation evidencing the timing and performance of these checks was not retained. Questioned costs: None. Context: Four of the five covered transactions selected did not have proper supporting documentation for suspension and debarment procedures. Cause: For three of the transactions tested, the City relied on cooperative purchasing agreements. Accordingly, the City did not perform or retain documentation of its own suspension and debarment verification. For the remaining transaction, documentation evidencing suspension and debarment compliance was not retained. Effect: The City did not have a documented control to perform and retain evidence of suspension and debarment verification at the time of award, as required by 2 CFR 200.303. Repeat Finding: No. Recommendation: We recommend the City obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM.gov. Views of responsible officials: There is no disagreement with the audit finding.
Suspension and Debarment Control Every Student Succeeds Act/Preschool Development Grants FFAL #93.434 Passed through from the Oklahoma Department of Human Services Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Criteria: Per 2 CFR 200.214, non federal entities must not enter into covered transactions with parties that are suspended or debarred. Acceptable verification methods include: • Checking the Exclusions section of SAM.gov, • Collecting vendor certifications regarding suspension/debarment status, or • Including appropriate suspension and debarment clauses in contracts. Internal controls must ensure these verifications are performed and documented. Condition: While a control appears to be in place for suspension and debarment, the Foundation could not support a control to verify whether all vendors paid with federal funds were suspended or debarred from participating in federal programs prior to entering into those transactions. For one procurement transactions selected for testing, the Foundation did not perform or document and retain any suspension and debarment verification procedures, such as checking SAM.gov, obtaining vendor certifications, or including suspension/debarment clauses in contracts. Cause: While the Foundation has established a formal internal control process to ensure suspension and debarment checks are performed before entering into covered transactions, it appears that not applicable transactions were captured in this process. Effect: The absence of a control that captures all applicable transactions creates a possibility that suspension and debarment requirements could occur and not be prevented or detected. Although no suspended or debarred vendors were identified through auditor performed SAM.gov searches, the deficiency increases the risk of entering into prohibited transactions in future periods. Context: We tested 1 vendor with procurement transactions totaling approximately $283,800 in federal expenditures. The Foundation did not maintain evidence of suspension and debarment verification for the one vendor tested. Independent auditor verification through SAM.gov confirmed that the vendor tested was not suspended or debarred. Nonstatistical sampling was used.Repeat Finding From Prior Year: No Questioned Costs: None, no vendor was listed as suspended or debarred. Recommendation: We recommend that The Foundation establish, document, and implement formal controls to ensure suspension and debarment verifications are completed prior to awarding covered transactions. Controls may include: • Performing and retaining SAM.gov verification printouts; • Obtaining annual or per transaction vendor certification statements; or • Incorporating a suspension and debarment clause into procurement contracts. Views of Responsible Officials: We do agree with the finding on suspension and debarment control on the FY2025 audit and have modified our procedures to include all covered transactions moving forward.
Assistance Listing, Federal Agency, and Program Name 21.027 COVID 19 Coronavirus State and Local Fiscal Recovery Funds and 84.215 Innovative Approaches to Literacy Federal Award Identification Number and Year Coronavirus State and Local Fiscal Recovery Funds SLFRP1027 Innovative Approaches to Literacy S215K230129 Pass through Entity 21.027 Michigan Strategic Fund; 20 Fathoms; Lean Rocket Lab; Talent First Inc; Lansing Economic Area Partnership; Michigan Economic Development Corporation 84.215 N/A Finding Type Significant Deficiency Repeat Finding No Criteria Recipients of federal awards are required to follow their internal purchasing policies, as well as comply with purchasing standards set forth in the Uniform Guidance. Per the University policy, all grant funded purchases in excess of $25,000 should be verified using SAM.gov the supplier is not suspended or debarred and the results should be retained in the purchase requisition. As Uniform Guidance restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal award (CFR 200.214). Condition In accordance with the University's policy, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Coronavirus State and Local Fiscal Recovery Funds. In accordance with the University's policy, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Innovative Approaches to Literacy. Questioned Costs None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A Identification of How Questioned Costs Were Computed N/A Context In the samples mentioned above, In accordance with University's policy the University did not maintain the appropriate documentation for the vendors to support their assessment of whether the vendors where included on Suspension or Debarment list. In either case the vendors included in the samples were not included in the Suspension and Debarment list and the University was allowed to contract with the vendor. Cause and Effect The University did not follow its policy to ensure that the documentation verifying the vendors were not suspended or debarred. Recommendation We recommend the University reviews its procedures and controls to ensure documentation of its compliance with the requirements under uniform guidance is maintained. Views of Responsible Officials and Planned Corrective Actions A new custom validation warning will be added to the requisitions business process at the buyer approval step to require the Procurement Specialist to verify SAM.gov and attach the results as required for grant funded purchases. This custom validation will ensure that each required consideration of suspension and debarment occurs and is documented in the procurement record.
FINDING 2025-004 Subject: Special Education Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: COVID-19 - Special Education Grants to States Assistance Listings Number: 84.027X Federal Award Number and Year (or Other Identifying Number): 22611-019-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Other Matters Condition and Context Procurement Small purchases, procurements between $50,000 and $150,000, require three quotes to be obtained and a contract awarded. There was one disbursement tested for $52,598 for small purchase procurement, and, while the appropriate number of quotes were obtained, a contract was not awarded for the transaction as required by Indiana Code 5-22-8-3. Suspension and Debarment Prior to entering into subawards and covered transactions with the Special Education Cluster (IDEA) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the System for Award Management (SAM) Excluded Parties List System (EPLS), collecting a certification from that person or entity, or adding a clause or condition to the covered transaction with that person or entity. It was determined that the School Corporation had a process in place to verify that vendors were not suspended or debarred, but the process was not operating effectively. For the one vendor tested also related to the transaction noted above, documentation of the SAM.gov search could not be provided. INDIANA STATE BOARD OF ACCOUNTS 20 OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were isolated to the transaction and award number noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.214 states: "Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will 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. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . INDIANA STATE BOARD OF ACCOUNTS 21 OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Small purchases— (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Indiana Code 5-22-8-3 states: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). (b) A purchasing agent may purchase supplies under this section by inviting quotes from at least three (3) persons known to deal in the lines or classes of supplies to be purchased. (c) The purchasing agent shall mail an invitation to quote to the persons described in subsection (b) at least seven (7) days before the time fixed for receiving quotes. (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. (e) The purchasing agent may reject all quotes. (f) If the purchasing agent does not receive a quote from a responsible and responsive offeror, the purchasing agent may purchase the supplies under IC 5-22-10-10." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS, or (b) Collecting a certification from that person if allowed by this rule, or (c) Adding a clause or condition to the covered transaction with that person." Cause The School Corporation was not aware of the Indiana Code requirement to enter into a contract for the equipment purchase. The School Corporation was aware of the requirements to check for suspension and debarment, but due to newer personnel at the School Corporation they were not able to locate the records or verify that the suspension and debarment verification was performed. INDIANA STATE BOARD OF ACCOUNTS 22 OAK HILL UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to design and implement an effective internal control system enabled noncompliance to remain undetected. Noncompliance with the provisions of federal statutes, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation amend its procurement policy and system of internal controls to ensure that procurement requirements meet the stricter federal and/or state requirements. Additionally, the internal control system effectiveness should be improved to ensure all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into contracts. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number: SLFRP1134 Pass-Through Agency: New Hampshire Governor’s Office for Emergency Relief and Recovery Pass-Through Number(s): Unknown Award Period: July 1, 2024 – June 30, 2025 Compliance Requirement: Suspension and Debarment Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal 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. Condition and Context: For one (1) of five (5) vendors tested, documentation was not provided to support that the City verified the vendor was not suspended or debarred from participation in federal assistant programs or activities. Questioned costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in federal programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ suspension or debarment status could cause federal grant funds to be expended to vendors that are excluded from participation in federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure that documentation of verification of vendors’ suspension and debarment status is obtained prior to executing transactions. Views of responsible officials: Management agrees with the finding.
Criteria or specific requirement: 2 CFR 200.214 Suspension and Debarment restricts 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. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Kansas Department of Health and Environment (Department) was unable to provide supporting documentation that it had performed suspension and debarment verification procedures before the start of procurement contracts. Questioned costs: None. Context: Sixty transactions were selected for testing which included twenty-five contracts and thirty-five subawards. For twenty-five of twenty-five contracts (100%), the Department was unable to provide documentation supporting when it had verified the contractors’ suspension and debarment status. The Department provided auditors with documentation that the contractors were not suspended or debarred, however, auditors were not able to verify that the status was documented prior to the start of the contracts. No exceptions were noted for the thirty-five subawards tested. Cause: The Department’s procedures and internal controls are not sufficient to ensure that it verifies and properly documents contractors’ suspension and debarment status prior to the execution of contracts. Effect: Failure to perform suspension and debarment verification procedures before the procurement of good or services could result in the payment of federal funds to contractors that are ineligible to participate in federal assistance programs. Repeat Finding: Yes, Finding 2024 - 007 Recommendation: We recommend that the Department enhances its procedures and internal controls to ensure that it verifies and maintains documentation of its contractors’ suspension and debarment status prior to the execution of all contracts. Verification can be performed by either checking SAM exclusions and maintaining documentation when the verification occurred, collecting a signed certification from the contractor prior to contract execution, or adding a clause or condition to the contract. We further recommend that documentation is readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
FINDING 2025-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Other Matters Condition and Context Suspension & Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods or services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. Verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. INDIANA STATE BOARD OF ACCOUNTS 19 NORTHWESTERN SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation had not properly implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. During the audit period, covered transactions in the amount of $63,597 were entered into with one vendor. The School Corporation had not checked the EPLS to verify the vendor was neither suspended nor debarred. The lack of internal controls and noncompliance were systemic throughout the audit period. Procurement During both the 2023-2024 and the 2024-2025 fiscal years, the School Corporation made payments to one vendor tested for micro-purchases for E-Funds via wire transactions that were automatically debited from their account without review prior to payment. Additionally, these transactions were not included within the Allowance of Claims reports presented to and approved by the School Board. The lack of internal controls is isolated to these specific E-Fund transactions with this vendor. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this 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." 2 CFR 200.214 states: "Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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." INDIANA STATE BOARD OF ACCOUNTS 20 NORTHWESTERN SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not implemented a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without designing and implementing an effective internal control system, material noncompliance was able to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2025-006 U.S. Department of Treasury, Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds (SLRF) Program for the period of July 1, 2024, through June 30, 2025 Criteria: In accordance with 2 CFR part 180 and 2 CFR §200.214, non-federal entities are prohibited from entering into contracts or making subawards to parties that are suspended or debarred from participation in federal programs. Entities must verify vendor eligibility through the System of Awards Management (SAM.gov), obtain a vendor certification documenting compliance, or add a clause or condition in the contract for that vendor. Condition: Of the five vendors tested, three did not have documented evidence the City performed the required suspension and debarment verification. Cause: The City uses SLRF funds to fill budget gaps caused by the pandemic’s economic fallout. The City did not procure all contracts with the expectation they would be paid for with federal funds. Therefore, suspension and debarment procedures were not verified in all cases. Effect: Without proper verification, there is an increased risk that federal funds could be expended on vendors who are suspended or debarred, which may result in noncompliance with federal regulations and potential repayment of funds. Recommendation: We recommend the City review their existing contracts to ensure documentation of suspension and debarment compliance has been obtained for all vendors paid with SLRF grants. Questioned Costs: None.
Finding 2025-006 - Procurement and Suspension and Debarment Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number (ALN): 21.027 Federal Agency: U.S. Department of the Treasury Pass-Through Grantor: Wyoming Office of State Lands and Investments (OSLI) Grant Year: 2021 Federal Program: Clean Water State Revolving Fund Assistance Listing Number (ALN): 66.458 Federal Agency: U.S. Environmental Protection Agency Pass-Through Grantor: Wyoming Office of State Lands and Investments (OSLI) Grant Year: 2024 Criteria Government-wide requirements for nonprocurement suspension and debarment are contained in 2 CFR Part 180 and 2 CFR 200.214. Non-Federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Prior to entering into covered transactions expected to equal or exceed $25,000, the non-Federal entity must verify that the vendor is not suspended or debarred. Verification may be accomplished by checking the System for Award Management (SAM.gov) or through other acceptable methods as outlined in federal regulations. Condition The City did not perform or document verification procedures to ensure that contractors used in the program were not suspended or debarred prior to entering into covered transactions. Independently we reviewed that the contractors were not suspended or debarred. Cause: The City does not have a control system in place to ensure that the required suspension and debarment is verified and documented. Effect or Potential Effect Failure to verify that contractors were not suspended or debarred resulted in noncompliance with federal procurement requirements. As a result, there is an increased risk that federal funds could be paid to ineligible contractors. If contractors used in the program had been suspended or debarred, the City could be required to repay the granting agency for the related expenditures. Questioned Costs None Context For the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds grant, of the 16 covered transactions tested, the City did not maintain formal documentation for any of the 16 transactions to demonstrate that the vendors were not suspended or debarred. For the Clean Water State Revolving Fund grant, of the 23 covered transactions tested, the City did not maintain formal documentation for 9 transactions to demonstrate that the vendors were not suspended or debarred. Acceptable documentation may include a certification from the vendor, a suspension and debarment clause included in the contract, or evidence of a SAM.gov search performed and retained in the procurement file. Identification as a repeat finding This is not a repeat finding. Recommendation We recommend the City strengthen its procurement procedures to ensure suspension and debarment verification is performed and documented prior to entering into covered transactions funded with federal awards. Verification may be accomplished by checking System for Award Management (SAM.gov), obtaining vendor certification, or including a suspension and debarment certification in the contract. Views of Responsible Officials Management concurs with the finding. See Corrective Action Plan.
Federal program – Child Nutrition Cluster – Assistance Listing Numbers 10.553 (School Breakfast Program), 10.555 (National School Lunch Program), and 10.559 (Summer Food Service Program for Children) – U.S. Department of Agriculture Program Year 2024–2025 Criteria or specific requirement – Suspension and debarment – 2 CFR §200.214 Condition – During our audit, documentation supporting verification of the suspension and debarment status was not able to be provided for a vendor with which a new covered transaction was entered. However, the vendor is not currently registered as being suspended or debarred. Cause – District procedures are designed to verify suspension and debarment status only upon initial vendor setup and do not require verification upon execution of each new covered transaction with an existing vendor. Effect or potential effect – This condition increases the risk that covered transactions could be entered into with vendors that may become suspended or debarred after initial vendor setup, which could result in noncompliance with federal requirements if not addressed. Questioned Costs – N/A Context – Out of a population of five vendors with which a covered transaction was entered into during the period, one was selected for testing. Documentation supporting the verification of the suspension and debarment status for this vendor was not able to be provided. Our sample was not, and was not intended to be, statistically valid. Identification as a repeat finding, if applicable – N/A Recommendation – We recommend the District update its policies and procedures to require suspension and debarment verification for all covered transactions, including those involving existing vendors, either prior to contract execution or award or on an annual basis. The District should also ensure such reviews are documented and retained in accordance with federal record retention requirements. Views of responsible officials and planned corrective action – Management agrees with this finding.
Federal Agency: Department of Education Federal Program Name: Wisconsin Charter Schools Program Waiver Cohort Assistance Listing Number: 84.282 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2025-138005-DPI-WCSPWC1-360 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria: 2 CFR Section 200.214 of the Uniform Guidance details suspension and debarment requirements for non-federal entities. Condition: One City Schools, Inc. did not document suspension and debarment considerations in accordance with the Uniform Guidance. Questioned costs: None Context: We sampled 5 procurement transactions, noting that none of them had documentation ensuring the vendor was not suspended or debarred. Cause: Policies and procedures were put in place, but were not being followed. Effect: This could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: Yes (2024-003) Recommendation: We recommend that the Organization maintain effective internal controls over suspension and debarment requirements. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing internal controls over suspension and debarment.
2025-001 - Procurement, Debarment and Suspension Federal Program Information: U.S. Department of the Treasury, passed through the Vermont Department of Public Safety CFDA - 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria: The following CFRs apply to this finding: 2 CFR 200.214, 2 CFR section 200.317-200.327 Condition: During audit procedures it was identified that the Town did not check sam.gov to confirm that the contractor was not debarred or suspended from receiving federal funds nor did they request a Suspension and Debarment certification from the contractor. Cause: The Town does not have the necessary internal controls over compliance. Effect: Contracts may be awarded to contractors that are debarred or suspended from working on federally funded projects. Identification of Questioned Costs: None Identified. Context: Two contracts were reviewed out of three. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Town revise its procurement policy to fully incorporate all elements required by 2 CFR §200.317-200.327. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan.
Information on the federal program: Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods Criteria or specific requirement: Procurement and Suspension and Debarment In accordance with 2 CFR 200.219 and 200.220, non-Federal entities must conduct procurements in a manner providing full and open competition and maintain documentation supporting the procurement method and the basis for contractor selection. Noncompetitive (sole source) procurement is permitted only under specific circumstances and generally requires adequate written justification and applicable approvals prior to contract execution. In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g. , grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: During our testing of procurement transactions, we noted that the Institute entered into a contract with a vendor using a noncompetitive/sole source method. However, the sole source justification was not completed and approved prior to execution of the contract and expenditures were charged to the federal grant. In addition, suspension and debarment checks were not completed for vendor. Cause: Miscommunication between departments within the Institute. Effect of Potential Effect: Failure to complete sole source documentation and suspension and debarment checks prior to award of the contract results in noncompliance with federal requirements and increases the risk that costs could be considered unallowable and federal funds could be paid to entities that are suspended or debarred. Questioned Costs: None noted. Context: We selected a sample of one vendor out of a population of four for procurement testing. This vendor was also selected for suspension and debarment testing out of a population of three vendors and subrecipients. Total expenditures charged to Federal grants under this contract was $26,850. The noncompetitive/sole source documentation and vendor suspension and debarment check were not completed and approved prior to execution of the contract and expenditures were charged to the Federal grant. It was noted after subsequent check that the subrecipient was not suspended or debarred. This sample was not intended to be, and was not, a statistically valid sample Identification as a Repeat Finding: 2023-002 Recommendation: Noncompetitive/sole source procurement documentation and suspension and debarment checks should be prepared, reviewed and approved before executing contracts and before charging costs to Federal grants. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the stated finding and has implemented a corrective action plan.
Finding Number: 2025‐001 Repeat Finding: No Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: Department of Treasury Federal Award Number: WCG2023‐‐00008 Pass‐Through Agency: Water Infrastructure Finance Authority of Arizona Questioned Costs: N/A Type of Finding: Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. Subrecipients must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. 2 CFR §§200.214 requires that vendors are checked to ensure they are not suspended or debarred from receiving federal funds. Condition The District did not follow Federal and State regulations governing procurement. Cause The District did not have policies and procedures in place to verify a vendor was not suspended or debarred. Effect The District was not in compliance with Federal and State regulations governing procurement. Context The sample was not intended to be, and was not, a statistically valid sample. For two vendors reviewed for suspension and debarment check requirements, the District did not maintain verification that the vendor was not suspended or debarred. Upon review of the vendors, neither were suspended or debarred. Recommendation The District should implement policies and procedures over procurement, specifically suspension and debarment, to ensure goods and services are procured through vendors who are not suspended or debarred, so that federal monies exceeding the formal procurement threshold are used appropriately. Views of Responsible Officials See Corrective Action Plan.
Federal Agency: 84 – Department of Education Federal Program Title: Higher Education Institutional Aid Assistance Listing Number: 84.031 Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 2 CFR §200.214, non-Federal entities must comply with the requirements of 2 CFR Part 180, which adopts the governmentwide requirements for suspension and debarment. These requirements prohibit non-Federal entities from entering into covered transactions with parties that are suspended or debarred and require verification of eligibility prior to entering into such transactions. Condition/Context: During our testing of Suspension and Debarment compliance, we selected a sample of 4 contracts under the Higher Education Institutional Aid program. We noted that for 1 of the 4 contracts tested, suspension and debarment verification was not completed prior to the contract date. Questioned Costs: $45,000 Effect: Failure to verify suspension and debarment status prior to contract execution increases the risk that the UEC could enter into covered transactions with suspended or debarred parties, resulting in noncompliance with Federal requirements. Cause: The UEC’s internal controls did not consistently ensure that suspension and debarment verification procedures were completed prior to contract execution. Repeat Finding: No. Recommendation: We recommend the UEC strengthen its procurement procedures to ensure suspension and debarment verification is consistently performed and documented prior to entering into covered transactions funded with Federal awards. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.