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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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
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
FINDING 2023-029 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Procurement and Suspension and Debarment - Suspension and Debarment Process See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not have an adequate process to ensure the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) subrecipients were not suspended or debarred prior to its plans to enter into grant agreements for 3 of the 5 sampled subrecipients. Criteria Federal regulation 2 CFR 180.300 requires when MDE enters into a covered transaction with a subrecipient with whom it plans to do business, it must verify that the subrecipient is not suspended or debarred. This can be accomplished by checking the federal website, collecting a certification, or adding a clause or condition to the covered transaction agreement. Cause For 2 subrecipients, MDE believes the reference to the entire Uniform Guidance (federal regulation 2 CFR 200) in the grant agreement constitutes verification the subrecipients are not suspended or debarred; therefore, MDE did not add a specific suspension or debarment clause or cite the specific suspension and debarment regulation (federal regulation 2 CFR 200.214). For the other subrecipient, MDE informed us its process was not always sufficient to ensure document retention of its verification to the federal website. Effect An increased risk exists that MDE could provide grant funds to suspended or debarred subrecipients. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. We reviewed the federal website and noted these 3 subrecipients were not suspended or debarred; therefore, we did not question the costs. Recommendation We recommend MDE establish an adequate process to ensure CSLFRF subrecipients are not suspended or debarred prior to its plans to enter into grant agreements. Management Views MDE agrees with the finding.
Finding 2023-003: Suspension and Debarment Information About the Program: All Programs Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. NFHA) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-Federal entity is 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: During our audit, we noted NFHA did not perform checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: Management did not have effective internal controls in place to ensure that suspension and debarment checks were being performed prior to entering into contracts with vendors or contractors/ consultants.Potential Effect: NFHA is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended, debarred, or otherwise excluded from contracting with the U.S. Federal Government. If a non-Federal entity knowingly does business with an excluded person, the agency responsible for NFHA's funding may disallow costs, annul or terminate the transaction, issue a stop work order, debar or suspend NFHA, or take other remedies as appropriate. Questioned Costs: None. Context: NFHA failed to perform its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend NFHA implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening, at a minimum, of any current vendors, contractors, or consultants as well.
Finding 2023-003: Suspension and Debarment Information About the Program: All Programs Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. NFHA) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-Federal entity is 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: During our audit, we noted NFHA did not perform checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: Management did not have effective internal controls in place to ensure that suspension and debarment checks were being performed prior to entering into contracts with vendors or contractors/ consultants.Potential Effect: NFHA is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended, debarred, or otherwise excluded from contracting with the U.S. Federal Government. If a non-Federal entity knowingly does business with an excluded person, the agency responsible for NFHA's funding may disallow costs, annul or terminate the transaction, issue a stop work order, debar or suspend NFHA, or take other remedies as appropriate. Questioned Costs: None. Context: NFHA failed to perform its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend NFHA implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening, at a minimum, of any current vendors, contractors, or consultants as well.