2 CFR 200 § 200.214

Findings Citing § 200.214

Suspension and debarment.

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About this section
Section 200.214 states that recipients and subrecipients must follow rules that prevent certain individuals or entities from receiving federal funds if they are debarred or suspended. This affects anyone involved in federal awards, ensuring that only eligible parties can participate.
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FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
University of Guam
Compliance Requirement: I
Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwis...

Finding No.: 2023-002 Federal Agency: Various AL Program: COVID-19 – 84.425 Education Stabilization Fund R&D Cluster Federal Award No.: Various Area: Suspension and Debarment Questioned Costs: $0 Criteria: In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: The University represented that it performs regular verification from SAM Exclusions, however, no formal documentation is kept on procurement files as evidence of procedures performed. Cause: The University did not properly document that verification was performed to identify if the selected person or entity in the covered transaction was not suspended or debarred prior to transacting with them. Effect: The University is in noncompliance with the applicable requirement. Recommendation: The University should revisit and implement its procedures to ensure that vendors and entities that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: See Corrective Action Plan.

FY End: 2023-09-30
Community Mental Health Services of Livingston County
Compliance Requirement: I
2023-001 – Suspension and Debarment Finding Type: Significant Deficiency in internal control over compliance Program: ALN 14.267 – Supportive Housing Program 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 otherwis...

2023-001 – Suspension and Debarment Finding Type: Significant Deficiency in internal control over compliance Program: ALN 14.267 – Supportive Housing Program 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 or ineligible for participation in Federal assistance programs or activities Condition: The vendor used for this grant was not checked for suspension and debarment prior to execution of the contract. Also, the contract did not include certification that the vendor was not suspended or debarred. Cause: Management oversight. Questioned Cost: None. Recommendation: We recommend that the CMHSP update contract language to include certification that vendor is not suspended or debarred. View of Responsible Official: Management is in agreement with this recommendation

FY End: 2023-09-30
Community Mental Health Services of Livingston County
Compliance Requirement: I
2023-001 – Suspension and Debarment Finding Type: Significant Deficiency in internal control over compliance Program: ALN 14.267 – Supportive Housing Program 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 otherwis...

2023-001 – Suspension and Debarment Finding Type: Significant Deficiency in internal control over compliance Program: ALN 14.267 – Supportive Housing Program 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 or ineligible for participation in Federal assistance programs or activities Condition: The vendor used for this grant was not checked for suspension and debarment prior to execution of the contract. Also, the contract did not include certification that the vendor was not suspended or debarred. Cause: Management oversight. Questioned Cost: None. Recommendation: We recommend that the CMHSP update contract language to include certification that vendor is not suspended or debarred. View of Responsible Official: Management is in agreement with this recommendation

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