govern the performance of its employees engaged in the selection, award, and administration of contracts. Cause of Condition: Policies and procedures have not been designed and implemented to ensure compliance with all federal award requirements. Effect of Condition: This condition resulted in noncompliance with federal grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends county officials and department heads gain an understanding of federal programs awarded to Creek County. Internal control procedures should be designed and implemented to ensure compliance with federal requirements. Management Response: Chairman of the Board of County Commissioners and County Clerk: It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control, and add this to the handbook and it will be updated yearly, so that all conflict can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk's Office will work with the District Attorney's Office for proper language. Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (8. Procurement, Suspension & Debarment.) Section 200.308 General Procurement Standards reads as follows: (a) Documented procurement procedures. The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. (b) Oversight of contractors. Recipients and subrecipients must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. See also § 200.501(h). (c) Conflicts of interest. (1) The recipient or subrecipient must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. No employee, officer, agent, or board member with a real or apparent conflict of interest may participate in the selection, award, or administration of a contract supported by the Federal award. A conflict of interest includes when the employee, officer, agent, or board member, any member of their immediate family, their partner, or an organization that employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from an entity considered for a contract. An employee, officer, agent, and board member of the recipient or subrecipient may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors. However, the recipient or subrecipient may set standards for situations where the financial interest is not substantial or a gift is an unsolicited item of nominal value. The recipient's or subrecipient's standards of conduct must also provide for disciplinary actions to be applied for violations by its employees, officers, agents, or board members. (2) If the recipient or subrecipient has a parent, affiliate, or subsidiary organization that is not a State, local government, or Indian Tribe, the recipient or subrecipient must also maintain written standards of conduct covering organizational conflicts of interest. Organizational conflicts of interest mean that because of relationships with a parent company, affiliate, or subsidiary organization, the recipient or subrecipient is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. (d) Avoidance of unnecessary or duplicative items. The recipient's or subrecipient's procedures must avoid the acquisition of unnecessary or duplicative items. Consideration should be given to consolidating or breaking out procurements to obtain a more economical purchase. When appropriate, an analysis should be made between leasing and purchasing property or equipment to determine the most economical approach. (e) Procurement arrangements using strategic sourcing. When appropriate for the procurement or use of common or shared goods and services, recipients and subrecipients are encouraged to enter into State and local intergovernmental agreements or inter-entity agreements for procurement transactions. These or similar procurement arrangements using strategic sourcing may foster greater economy and efficiency. Documented procurement actions of this type (using strategic sourcing, shared services, and other similar procurement arrangements) will meet the competition requirements of this part. (f) Use of excess and surplus Federal property. The recipient or subrecipient is encouraged to use excess and surplus Federal property instead of purchasing new equipment and property when it is feasible and reduces project costs. (g) Use of value engineering clauses. When practical, the recipient or subrecipient is encouraged to use value engineering clauses in contracts for construction projects of sufficient size to offer reasonable opportunities for cost reductions. Value engineering means analyzing each contract item or task to ensure its essential function is provided at the overall lowest cost. (h) Responsible contractors. The recipient or subrecipient must award contracts only to responsible contractors that possess the ability to perform successfully under the terms and conditions of a proposed contract. The recipient or subrecipient must consider contractor integrity, public policy compliance, proper classification of employees (see the Fair Labor Standards Act, 29 U.S.C. 201, chapter 8), past performance record, and financial and technical resources when conducting a procurement transaction. See also § 200.214. (i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. (j) Time-and-materials type contracts. (1) The recipient or subrecipient may use a time-and-materials type contract only after a determination that no other contract is suitable and if the contract includes a ceiling price that the contractor exceeds at its own risk. Time-and-materials type contract means a contract whose cost to a recipient or subrecipient is the sum of: (i) The actual cost of materials; and (ii) Direct labor hours charged at fixed hourly rates that reflect wages, general and administrative expenses, and profit. (2) Because this formula generates an open-ended contract price, a time-and-materials contract provides no positive profit incentive to the contractor for cost control or labor efficiency. Therefore, each contract must set a ceiling price that the contractor exceeds at its own risk. Further, the recipient or subrecipient awarding such a contract must assert a high degree of oversight to obtain reasonable assurance that the contractor is using efficient methods and effective cost controls.
2025-003 Suspension and Disbarment Condition: The Organization did not research vendors of covered transactions for potential suspension or debarment. Criteria: Per Code of Federal Regulations 2 CFR 200.214, the Organization is prohibited from entering into contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Cause: The Organization did not have a procedure in place to research vendors for suspension and debarment. Effect: Although the audit did not identify any instances of noncompliance, the Organization did not research vendors for potential suspension and debarment and could have engaged with a vendor that was suspended or debarred. Recommendation: RBT recommends that the Organization establish policies and procedures requiring that the Organization verify and document vendors' suspension and debarment status prior to entering into contracts with the vendors. Management's Response: See corrective action plan.
Finding Reference Number: 2025-002 Reportable finding considered a significant deficiency - Inadequate Controls over Procurement documentation retention Program name and CFDA: Supportive Services for Veteran Families (SSVF) 64.033 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) 21.027 Federal award identification number: SSVF – 23-CA-437 CSLFRF – UNKNOWN Federal award year: SSVF – 10/1/2022-9/30/2025 CSLFRF – 8/1/2024-6/30/2025 Federal awarding agency: SSVF – Department of Veterans Affairs CSLFRF – Department of the Treasury Name of pass-through entity: SSVF – None CSLFRF – Alameda County Criteria Federal procurement requirements under 2 CFR 200.318–200.320 outline expectations for maintaining documentation to show procurement activity aligns with written procedures and promotes full and open competition. Additionally, 2 CFR 180.300, incorporated by 2 CFR 200.214, requires organizations to verify that vendors are not suspended or debarred before entering into an agreement. This verification can be completed by checking SAM.gov or obtaining a vendor certification. Statement of Condition Organization has written procurement procedures and consistently performs cost analyses for rental assistance-related procurements. Audit testing also confirmed that none of the vendors involved were suspended or debarred. However, the Organization was not able to provide documentation showing that suspension/debarment checks were performed before onboarding these vendors. While the procedures appear to be followed in practice, the documentation step was not retained. Cause It appears that documentation was not transitioned between staff members when the individual who initially performed these procedures left the organization. Effect or Potential Effect Without documentation of these checks, the Organization cannot fully demonstrate compliance with federal procurement and suspension/debarment requirements. Although no ineligible vendors were used, the missing documentation increases the risk that future procurements could be questioned or require additional follow-up. Questioned Costs None Recommendation We recommend the Organization take a few steps to strengthen this process going forward: Incorporate a simple, consistent step for keeping documentation of SAM.gov checks or vendor certifications in each procurement file. Communicate this requirement to the staff performing vendor onboarding so expectations are clear. Periodically review procurement files to make sure documentation is being consistently retained. These adjustments should help ensure the strong practices already in place are fully supported by required documentation. Reportable Views of Responsible Officials See corrective action plan.
Identification of the Federal Program: Assistance Listing Number: 16.922 Assistance Listing Title: Equitable Sharing Program Federal Agency: U.S. Department of the Justice Federal Award Identification Number: N/A Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Prior to entering into subawards and contracts with award funds, recipients must ensure that contractors and subcontractors are not suspended, debarred, or otherwise excluded from participation in federally funded programs pursuant to 2 CFR Part 180 and 2 CFR §200.214. Condition: During the audit, we noticed that the City did not perform suspension and debarment checks on the contractors that they hired with Asset Forfeiture monies. Cause: The City does not have formal policies and procedures in place to ensure the suspension and debarment review process over vendors that provides goods or services to the City’s programs was conducted prior to entering into a contract. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects prior to the contract being awarded, the City could be contracting with vendors that are prohibited from working on federally funded projects and incurring potentially disallowed costs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: No. Recommendation: We recommended the City develop policies and procedures to incorporate the suspension and debarment verification prior to awarding contracts. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.
2025-001 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Material Weakness in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for nine covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Town is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of these vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The Town should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number: Not available Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number(s): Unknown Award Period: July 1, 2024 – June 30, 2025 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For each of the five (5) transactions tested, the Town did not have a documented verification that the vendor was not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that vendors were not suspended or debarred from participation in federal programs or activities. Effect: Lack of verification (or untimely verification) of vendors’ suspension or debarment status could cause federal grant funds to be expended to vendors that are excluded from participation in federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to ensure that the verification of vendors’ suspension and debarment status is documented prior to executing transactions. Views of responsible officials and planned corrective actions: Management agrees with the finding.
2025-004 Department of the Treasury Assistance Listing #21.027 Coronavirus State and Local Fiscal Recovery Funds for the period July 1, 2024, to June 30, 2025 Criteria: Recipients of the Coronavirus State and Local Fiscal Recovery Funds (ARPA) grant are required to follow the Uniform Guidance section § 200.214 Suspension and Debarment. Under that section, grant recipients are restricted from entering into contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. The Uniform Guidance also requires grant recipients to develop internal controls to ensure compliance with the grant requirements. Condition: The Town had two significant contracts under the ARPA grant that would have required documentation or certification of suspension and debarment from the vendors, but no documentation was obtained. In addition, the Town did not have procedures in place to ensure compliance with suspension and debarment requirements. Cause: The Town did not document a search of Sam.gov to ensure the vendors were not suspended nor debarred. As an alternative, the Town also did not receive certification from the vendors or any other documentation regarding their suspension and debarment status. Effect: The Town runs the risk that the Town will contract with a vendor that is suspended or debarred. Known Questioned Costs: None Likely Questioned Costs: None Recommendations: The Town should have procedures in place to ensure it does not enter into a contract with a vendor that is suspended or debarred. In addition, any documentation of suspension and debarment status should be retained with the grant documentation.
2025-001 – Procurement, Suspension and Debarment Federal Program Information: Department of Education - Child Nutrition Cluster: CFDA - 10.553/10.555/10.559//10.582 Criteria: The following CFR(s) apply to this finding: 2 CFR 200.318 General procurement Standards and 2 CFR 200.214 Suspension and Debarment Condition: During audit procedures, it was identified that the Supervisory Union did not have internal controls in place to ensure that all appropriate procurement standards and procedures were followed. Cause: Unknown Effect: The Supervisory Union may not be consistently following all appropriate procurement standards and procedures. There were instances where the suspension and debarment verification were not performed. Identification of Questioned Costs: None identified. Context: Of the 8 procurement purchases tested, 6 were not verified for suspension or debarment in SAM.gov. Repeat Finding: This is a repeat finding of 2024-002. Recommendation: It is recommended that the Supervisory Union implements controls to ensure that it follows all appropriate procurement standards and procedures. We also recommend that the Supervisory Union review its procurement policy to ensure that it is updated and complete.
2025-001 U.S. Department of Education, Assistance Listing #84.027/84.173 Special Education Cluster (IDEA) Program and U.S. Department of Treasury, Assistance Listing #21.027 Coronavirus State and Local Fiscal Recovery Funds (SLRF) Program for the period of July 1, 2024, through June 30, 2025 Criteria: Uniform Guidance section 2 CFR §200.317-200.327 Procurement Standards, requires purchases exceeding the micro-purchase threshold of $10,000 to follow small purchase procedures, which require obtaining price or rate quotations from an adequate number of qualified sources (§200.320) prior to entering into a contract. In addition, 2 CFR Part 180 and 2 CFR §200.214 require non-federal entities to verify if contractors are suspended or debarred (e.g., Sam.gov check or certification) and include appropriate contract clauses in applicable contracts. Condition: The School Department did not obtain price or rate quotations for two projects that exceeded the micro-purchase threshold. Additionally, the Department did not perform, or document required suspension and debarment procedures for the contractor (e.g., verification against SAM.gov, obtaining certifications, or including contract clauses). The City did not perform, or document required suspension and debarment procedures for the contractor (e.g., verification against SAM.gov, obtaining certifications, or including contract clauses) for three of the six contracts tested. Cause: School staff were not aware the projects would be funded with federal funds and did not ensure compliance with federal requirements for competitive pricing and suspension/debarment verification. City staff were not aware projects covered under the SLRF definition of “revenue replacement”, which excludes most procurement requirements, are still required to follow 2 CFR Part 180 and 2 CFR §200.214. Effect: Failure to obtain competitive quotes and verify contractor eligibility to receive Federal funds increases the risk of noncompliance, inefficient use of federal funds, and potential disallowance of costs. Known Questioned Costs: $61,891 for #84.027/84.173; $51,750 for #21.027 Likely Questioned Costs: $12,799 for #21.027 Recommendation: We recommend training staff on procurement and suspension/debarment requirements and implementing a pre-award compliance checklist. We also recommend increasing communication between grant personnel and facilities management personnel so all parties are aware which projects will be funded with federal funds.
FINDING 2025-003 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other identifying Numbers): 22611-133-PN01, 23611-133-PN01, 24611-133-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 19 LEWIS CASS SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The internal control system in place at the School Corporation was not effective in ensuring compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, the informal procurement method is permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. A total of two vendors were determined to require small purchase procedures, totaling $123,078. For the two vendors tested, the School Corporation did not obtain price or rate quotations. Additionally, documentation detailing the history of procurement, which must include the reason for the procurement method used, was absent for those two vendors. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the System for Award Management (SAM) Excluded Parties List System (EPLS), collecting a certification from that person or entity, or adding a clause or condition to the covered transaction with that person or entity. A population of two covered transactions for goods or services totaling $123,078, both of which equaled or exceeded the $25,000 threshold paid from the special education funds during the audit period, were identified and selected for testing. For both transactions, the School Corporation did not verify that the vendor was not suspended, debarred, or otherwise excluded from or eligible for participation in federal assistance programs or activities prior to issuing payment. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 20 LEWIS CASS SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.214 states: "Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases— (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Cause The School Corporation did not have adequate internal controls to ensure compliance with procurement and suspension and debarment requirements. Effect The lack of an effective internal control system enabled material noncompliance to occur and remain undetected. Noncompliance with the Procurement and Suspension and Debarment compliance requirement could enable small purchases made by the School Corporation to be uncompetitive and could lead to contracting with vendors who are suspended or debarred from receiving federal grant funding. INDIANA STATE BOARD OF ACCOUNTS 21 LEWIS CASS SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the School Corporation develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are verified to not be suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number: Unknown Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number(s): GAE DOR 22ARPALOCPASSTHRU001 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition and Context: For one of one vendors tested, documentation was not provided to support that the Town verified the vendor was not suspended or debarred from participation in federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in federal programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ suspension or debarment status could cause federal grant funds to be expended to vendors that are excluded from participation in federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend the Town enhance procedures and controls to ensure that the verification of vendors’ suspension and debarment status is obtained and documented prior to executing transactions. This verification can be performed by checking the System for Award Management (SAM.gov), obtaining a written certification from the vendor, or including a contract clause stating that the vendor is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding.
2025-001 - Procurement, Debarment and Suspension Federal Program Information: U.S. Department of the Treasury, passed through the Vermont Department of Public Safety CFDA - 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria: The following CFRs apply to this finding: 2 CFR 200.214, 2 CFR section 200.317-200.327 Condition: During audit procedures it was identified that the Town did not check sam.gov to confirm that the contractor was not debarred or suspended from receiving federal funds nor did they request a Suspension and Debarment certification from the contractor. Cause: The Town does not have the necessary internal controls over compliance. Effect: Contracts may be awarded to contractors that are debarred or suspended from working on federally funded projects. Identification of Questioned Costs: None Identified. Context: Two contracts were reviewed out of three. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Town revise its procurement policy to fully incorporate all elements required by 2 CFR §200.317-200.327. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan.
LACK OF PROCEDURES TO ENSURE PROPER SUSPENSION AND DEBARMENT REQUIREMENTS Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant: SLFRP0923, March 3, 2021, through December 31, 2024 Federal Grantor: U.S. Department of the Treasury Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2023) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2023) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition: The County did not have controls in place to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay nine vendors over $25,000 each, totaling $1,387,268, during the fiscal year ended June 30, 2025. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. Context: The County did not have a system in place to ensure proper application of the federal guidelines for the federal disbursements. Effect: Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Cause: Lack of procedures and knowledge regarding suspension and debarment requirements. Questioned Costs: None Repeat Finding: Yes Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster State Administering Department: California Department of Aging ALN: 93.044, 93.045, 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2401CAOACM; October 1, 2023 – September 30, 2025 2401CAOAHD; October 1, 2023 – September 30, 2025 2401CAOANS; October 1, 2023 – September 30, 2025 2401CAOASS; October 1, 2023 – September 30, 2025 2501CAOACM; October 1, 2024 – September 30, 2026 2501CAOAHD; October 1, 2024 – September 30, 2026 2501CAOANS; October 1, 2024 – September 30, 2026 2501CAOASS; October 1, 2024 – September 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Title 2 – Federal Financial Assistance Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. § 200.303 - Internal controls (2 CFR 200.303): The recipient and subrecipient must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. §200.332 Requirements for passthrough entities (2 CFR 200.332): All pass-through entities must: (a) Verify that the subrecipient is not excluded or disqualified in accordance with §180.300. Verification methods are provided in §180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. Condition: Audit procedures included a review of eight subrecipient agreements to determine whether the Department complied with federal suspension and debarment requirements for covered transactions. The subrecipient agreements reviewed did not contain a suspension and debarment certification clause indicating that the subrecipient was not suspended or debarred from participation in federally funded programs. Furthermore, the Department was unable to provide documentation demonstrating that suspension and debarment verification procedures, such as a review of the System for Award Management (SAM), had been performed prior to entering into the covered transactions. As part of audit procedures, we independently verified the suspension and debarment status of all subrecipients tested through a review of the SAM Exclusions database and noted that none were suspended or debarred at the time of our testing. Questioned costs: None Context: See “Condition.” Cause: Controls designed to ensure compliance with federal suspension and debarment requirements were not operating with sufficient precision to verify and document the eligibility of subrecipients prior to entering into covered transactions. Specifically, personnel responsible for administering the program had not established or consistently performed procedures to verify suspension and debarment status through SAM or obtain required certifications, resulting in unsupported compliance with 2 CFR §200.214 and 2 CFR Part 180. Effect: Failure to verify and document suspension and debarment status prior to entering into covered transactions results in noncompliance with 2 CFR §180.300 and increases the risk that federal funds could be awarded to subrecipients that are suspended or debarred from participation in federally funded programs. Although the audit's independent verification determined that none of the subrecipients tested were suspended or debarred, the lack of documented verification procedures prevents the Department from demonstrating compliance with federal requirements and increases the risk that ineligible parties could be engaged in future transactions. Repeat finding: No Recommendation: The Department should review and strengthen its procedures for verifying the suspension and debarment status of subrecipients before entering into any agreement involving federal funds and ensure that the verification documentation is maintained. Alternatively, incorporate a clause in subrecipient contracts certification of their suspension or debarment status. Views of responsible officials: Management’s response is reported in “Management’s Response and Corrective Action Plan” included in a separate section at the end of this report.
Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Epidemiology and Laboratory Capacity for Program Infectious Diseases (ELC) State Administering Department: California Department of Public Health ALN: 93.323 Pass-Through Agency: Heluna Health Pass-Through Number(s): 95-2557063 Award Number and Period: NU50CK000539; August 1, 2019 – July 31, 2027 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Title 2 – Federal Financial Assistance Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. § 200.303 - Internal controls (2 CFR 200.303): The recipient and subrecipient must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). § 200.214 – Suspension and debarment. Non-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, subawards, and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter I – Office of Management and Budget Government-Wide Guidance for Grants and Agreements. Part 180 – OMB Guidelines to Agencies on Government- Wide Debarment and Suspension (Non-procurement). Subpart C – Responsibilities of Participants Regarding Transactions Doing Business With Other Persons §180.300 (2 CFR 180.300): When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You may do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or a condition to the covered transactions with that person. Condition: Audit procedures included a review of nine vendor contracts and eleven subrecipient agreements to determine whether the Department complied with federal suspension and debarment requirements for covered transactions. Of the nine vendor contracts reviewed, six (67%) did not contain a suspension and debarment certification clause indicating that the contractor was not suspended or debarred from participation in federally funded programs. In addition, all eleven (100%) subrecipient agreements reviewed did not contain a suspension and debarment certification clause indicating that the subrecipient was not suspended or debarred from participation in federally funded programs. Furthermore, the Department was unable to provide documentation demonstrating that suspension and debarment verification procedures, such as a review of the System for Award Management (SAM), had been performed prior to entering into the covered transactions. As part of audit procedures, we independently verified the suspension and debarment status of all vendors and subrecipients tested through a review of the SAM Exclusions database and noted that none were suspended or debarred at the time of our testing. However, the Department's records did not demonstrate compliance with the federal requirement to verify the eligibility of contractors and subrecipients prior to entering into covered transactions. This condition is not in compliance with the suspension and debarment requirements contained in 2 CFR Part 180, as adopted by 2 CFR §200.214. Questioned costs: None Context: See “Condition.” Cause: Controls designed to ensure compliance with federal suspension and debarment requirements were not operating with sufficient precision to verify and document the eligibility of contractors and subrecipients prior to entering into covered transactions. Specifically, personnel responsible for administering the ELC program had not established or consistently performed procedures to verify suspension and debarment status through SAM or obtain required certifications, resulting in unsupported compliance with 2 CFR §200.214 and 2 CFR Part 180. Effect: Failure to verify and document suspension and debarment status prior to entering into covered transactions results in noncompliance with 2 CFR §180.300 and increases the risk that federal funds could be awarded to contractors or subrecipients that are suspended or debarred from participation in federally funded programs. Although the audit's independent verification determined that none of the vendors or subrecipients tested were suspended or debarred, the lack of documented verification procedures prevents the Department from demonstrating compliance with federal requirements and increases the risk that ineligible parties could be engaged in future transactions. Repeat finding: Yes – 2024-008 Recommendation: Public Health should review and strengthen its procedures for verifying the suspension and debarment status of vendors and subrecipients before entering into any agreement involving federal funds and ensure that the verification documentation is maintained. Alternatively, incorporate a clause in vendor and subrecipient contracts certification of their suspension or debarment status. Views of responsible officials: Management’s response is reported in “Management’s Response and Corrective Action Plan” included in a separate section at the end of this report.
Reference Number: Prior Year Finding: 2025-011 N/A Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Audit documentation must be made available upon request to the cognizant or oversight agency for audit or its designee, cognizant agency for indirect cost, a Federal agency, or GAO at the completion of the audit, as part of a quality review, to resolve audit findings, or to carry out oversight responsibilities consistent with the purposes of this part. Access to audit documentation includes the right of Federal agencies to obtain copies of audit documentation as is reasonable and necessary. (2 CFR 200.517(b)) Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards (2 CFR 200.214). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City could not provide complete documentation to evidence the City ensured contractors were not suspended or debarred prior to entering into the contract. Context: Two of eight contracts selected for testing were not available for review. No contract information was provided for these agreements and therefore no support related to ensuring that a contractor was not suspended or debarred was available. In addition, for an additional three of eight contracts selected for testing, documentation did not contain the necessary suspension and debarment certifications or review checks. CITY OF MANCHESTER, NEW HAMPSHIRE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED JUNE 30, 2025 (27) Section III – Findings and Questioned Costs – Major Federal Programs (Continued) Cause: The City’s policies, procedures, and internal controls were not sufficient to ensure that contract files included or retained documentation supporting suspension and debarment verification checks. Effect: Without complete contract files and documented suspension and debarment verification, the City could not demonstrate compliance with Federal requirements. This increases the risk that Federal funds could be used in transactions with contractors that are suspended, debarred, or otherwise excluded from participation in Federal awards. Questioned costs: None. Recommendation: We recommend that the City strengthen its written policies, procedures, and internal controls to require suspension and debarment verifications before entering into Federally funded contracts and that verification be readily available for audit. Views of Responsible Officials: There is no disagreement with the finding.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of the Treasury Award Number and Year: 2021 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the City must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the City’s provisions for procurement requirements, we noted the following: • For seven (7) out of seven (7) contracts selected for testing, the City did not include the applicable provisions described in 2 CFR 200 Appendix II. • For seven (7) out of seven (7) contracts tested, we noted that there was no evidence that the City verified that the contracted entities were not suspended or debarred or otherwise excluded from participating in federal programs prior to entering the contract. Cause: The City did not follow their policy to verify the information described in the conditions prior to entering the transactions. The City’s policy does not include the requirement to include each of the applicable provisions identified in 2 CFR 200 Appendix II in its contracts or purchase orders. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of seven (7) out of fifteen (15) procurement contracts were tested. This represented a total of $23,361,562 in contracted services under the grant. Repeat Finding from Prior Year: No. Recommendation: We recommend the City strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials and Planned Corrective Action: Management agrees. See separately issued Corrective Action Plan.
Federal Program: ALN 93.600 Head Start Program ALN 10.536 CACFP Training Grants Category: Compliance/ internal control significant deficiency Compliance requirements: Procurement and Suspension/Debarment Condition: BGCPR did not document or maintain evidence of the required SAM.gov vendor eligibility verifications for procurement transactions charged to federal programs. Criteria: Pursuant to 2 CFR § 200.214 and 2 CFR § 180.300, recipients and subrecipients may not enter into covered transactions with parties that are debarred, suspended, or otherwise excluded from participation in Federal awards and must verify that vendors are not excluded or disqualified by checking SAM.gov exclusions, obtaining a certification, or including an appropriate contractual clause. BGCPR Fiscal Policies and Procedures, under the Cash Disbursements and Cash Allocations policies, require that all vendors be verified through the System for Award Management (SAM.gov) prior to establishing a commercial relationship and before disbursing funds. Cause: Although BGCPR's Fiscal Policies and Procedures require verification of vendors through SAM.gov prior to establishing a commercial relationship and before disbursing Federal funds, management did not consistently adhere to these established policies and procedures. As a result, vendor eligibility reviews were not performed or documented as required. Context: For 17 of 21 transactions tested, BGCPR did not perform or maintain documentation evidencing that vendors were verified through SAM.gov prior to entering into covered transactions, as required by Federal regulations. Consequently, BGCPR could not demonstrate that the vendors were not suspended, debarred, or otherwise excluded from participation in Federal programs at the time the transactions were executed. Questioned cost: None identified. During our audit procedures, we found no evidence indicating that the vendors tested were suspended, debarred, or otherwise excluded from participation in Federal programs. However, because the required verification was not performed or documented at the time of the transactions, compliance could not be demonstrated. Effect or potential effect: The failure to perform and document SAM.gov searches increase the risk that federal funds could be expended on transactions with vendors that are suspended, debarred, or otherwise excluded from participation in federal programs, resulting in noncompliance with federal procurement requirements. Recommendation: We recommend that management strengthen its procurement policies and procedures to require documented verification of all applicable vendors through SAM.gov before awarding contracts or making purchases with federal funds. Evidence of the verification should be retained in the procurement file and periodically monitored for compliance. Views of officials responsible: We acknowledge that internal control should be strengthened by reviewing the current BGCPR Fiscal Policy, and effective September 30, 2026, all vendors must be verified who are not excluded or disqualified at System for Award Management (SAM.gov). This verification will be incorporated into the Workflow system and maintained as part of the vendor approval process. Anticipated completion date: September 30, 2026
Federal Program: ALN 93.600 Head Start Program Category: Compliance/ internal control significant deficiency Compliance requirements: Procurement and Suspension/Debarment Condition: BGCPR did not follow its procurement policies in compliance with applicable State and Federal procurement requirements. Criteria: BGCPR’s Fiscal Policy Manual — VI. Cash Disbursements & Expense Allocations, Incoming Invoice Processing, item 2 established that vendors must be created in the Workflow system in accordance with established procedures. Documentation for new vendors must be obtained and reviewed for completeness and accuracy and must include, at a minimum, Form W-9, the new vendor form, and a valid Merchant Registration Certificate issued by the applicable local governmental agency. 2 CFR § 200.318(a) requires recipients and subrecipients to maintain and use documented procurement procedures for procurement transactions under a Federal award or subaward, including the acquisition of property or services. These procedures must be consistent with applicable State, local, and tribal laws and regulations and the Federal procurement standards. 2 CFR § 200.318(h) requires recipients and subrecipients to award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration must be given to contractor integrity, public policy compliance, proper classification of employees, past performance, and financial and technical resources. 2 CFR § 200.318(i) requires recipients and subrecipients to maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Under 2 CFR § 200.319(a), procurement transactions must provide full and open competition. When simplified acquisition procedures apply, § 200.320(a)(2)(i) requires price or rate quotations from an adequate number of qualified sources; noncompetitive procurement is permitted only under the circumstances in § 200.320(c) and must be supported by the procurement record. Under 2 CFR § 200.214 and Appendix II(H) to Part 200, contract awards must not be made to parties that are debarred, suspended, or otherwise excluded in SAM. Section 200.327 requires contracts under Federal awards to contain the applicable provisions in Appendix II. Cause: BGCPR did not consistently apply its procurement policies and did not have an effective pre-award and supervisory review control to confirm vendor eligibility, required competition and approvals, complete procurement documentation, and applicable contract provisions before purchase commitments and payments were made. Context: Of 21 procurement transactions tested: 7 samples did not have an available supplier merchant registration certificate; 5 samples did not evidence the required quotation process and/or purchase order and did not include a documented justification; and 3 samples had contracts of which 2 samples did not include a debarment and suspension provision. Effect or potential effect: The absence of required vendor documentation, competition support, purchase orders or documented justification, and debarment and suspension controls increases the risk that purchases may be made from unauthorized or excluded vendors, may not provide full and open competition, and may be unsupported or subject to questioned costs under the Federal award. Recommendation: We recommend that management strengthen and enforce procurement controls by: (1) requiring a current Puerto Rico Merchant Registration Certificate before award or purchase; (2) documenting the required quotations and purchase order, or an approved justification citing the allowable basis for a noncompetitive procurement; (3) performing and retaining a dated SAM.gov exclusion search before contract award and renewal; (4) using standardized contracts containing all applicable Federal provisions, including debarment and suspension language; and (5) requiring documented supervisory review of a procurement checklist before approval and payment. Views of officials responsible: BGCPR agrees with the deficiency identified, mostly attributable to employee turnover within the Finance Division. As a result of this, during fiscal year 2026-2027 BGCPR will implement procedures to ensure proper procurement process including the following: a. Review the procurement check list to ensure that all required documentation is included within and ensure revision before a purchase order is issued to the vendor. b. Training to the personnel to guarantee that policy and procedures are implemented as required. c. Enforce standardized procedures to ensure that all approvals are consistently documented and maintained in accordance with policy or grant requirements. Anticipated completion date: September 30, 2026
Federal Agency: US Deparment of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: COVID-19 ARPA (American Rescue Plan Act) Pass-Through Agency: N/A Pass-Through Number(s): N/A Compliance Requirement: Procurement – Suspension and Debarment Award Period: March 3, 2021 - December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Uniform Guidance (2 CFR §§200.214 and 200.318) prohibits non‑Federal entities from awarding contracts supported by Federal awards to parties that are suspended or debarred. In addition, 2 CFR §200.303 requires non‑Federal entities to establish and maintain effective internal control over Federal awards, including documented policies and procedures to ensure consistent compliance with Federal requirements. Verification of vendor eligibility is typically performed through review of the System for Award Management (SAM.gov) or equivalent documentation prior to contract execution. Condition: During our audit, we noted a deficiency related to suspension and debarment verification and documentation. Specifically, for the procurement transactions tested, Worcester County, Maryland did not document verification that the vendor was not suspended or debarred prior to contract execution. In addition, the County does not have a formally documented suspension and debarment policy. While management indicated that suspension and debarment checks may be performed in practice, the absence of written policies and procedures resulted in inconsistent application and documentation of this required compliance procedure. Questioned costs: N/A Context: Uniform Guidance requires non‑federal entities to ensure that vendors and contractors receiving federal funds are not suspended or debarred from participating in federally funded programs. Effective compliance with this requirement is supported by documented policies and procedures that require verification (e.g., review of the System for Award Management (SAM.gov)) prior to entering into contracts. Cause: The County had not formally documented policies and procedures related to suspension and debarment verification and relied on informal practices and staff knowledge. As a result, suspension and debarment checks were not consistently documented or retained prior to contract execution. Effect: Failure to consistently document suspension and debarment verification increases the risk that the County may enter into contracts with vendors that are ineligible to participate in federally funded programs. While no instances of contracting with suspended or debarred vendors were identified and no questioned costs were noted, these conditions represent noncompliance with Federal procurement documentation requirements and reduce the County’s ability to demonstrate consistent adherence to Uniform Guidance. Repeat Finding: No. Recommendation: We recommend that the County develop and formally document a suspension and debarment policy that requires verification and documentation of vendor eligibility (e.g., SAM.gov review) for all contracts supported by Federal awards prior to execution of the contract. Management should also consider implementing standardized checklists or review controls to promote consistent compliance. Views of Responsible Officials and Planned Corrective Actions: Management concurs. Worcester County plans to update the County purchasing, financial and grant policies to ensure debarment and suspension compliance by implementing procedures aligned with the U.S. Office of Management and Budget Uniform Guidance (primarily 2 CFR Part 200) and the governmentwide debarment rules in 2 CFR Part 180, as adopted by the awarding agency. The corrective action includes implementing a written procurement policy which states that the county will not contract with or issue subawards to parties that are suspended or debarred when federal funds are involved. The Grant/Budget Office will maintain open communication with Procurement regarding federally funded grant projects that will be advertised for bid. After bids are received and before the evaluation committee reviews or recommends an award, the Grant/Budget Office will search the System for Award Management (SAM.gov) exclusion database for each vendor that submitted a bid. A PDF or screenshot of the SAM search for each vendor will be retained in a grant and procurement file. All other federal grants under procurement threshold will need county departments to reach out to the Grant/Budget office before choosing vendors. Departments will need to list their potential vendors for the federal grant and email the Grant/Budget office for debarment verification before moving forward with expending federal grant funding. A PDF or screenshot of the SAM search for each vendor will be sent to the department and a copy kept by Grants/Budget office as well.
Finding: This is a new finding relating to a significant deficiency in internal control over compliance in relation to the procurement suspension and debarment requirements of the above noted major federal program. Criteria: The 2025 Uniform Guidance compliance supplement issued by the Office of Management and Budget in November of 2025 outlines the period of performance compliance guidelines and requirements of the above noted major federal program. It states, “Recipients may use award funds to enter into contracts to procure goods and services necessary to implement one or more of the eligible purposes outlined in 42 USC sections 802(c) and 803(c) and Treasury's 2021 Interim Final Rule, 2022 Final Rule, and 2023 Interim Final Rule. As such, except as noted in the next paragraph, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. In July 2022, Treasury released SLFRF FAQ 13.15, which explains that only a subset of the requirements in Subparts D and E of the Uniform Guidance apply to recipients' use of award funds under the revenue loss eligible use category. The requirements of 2 CFR sections 200.318 through 200.327 are not included in the list of requirements applicable to such funds.” However, Subpart C of the Uniform Guidance 2 CFR section 200.214 states, “Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards.” Condition: As part of the current fiscal year audit, the Bid Ordinance and Charter of the Town were reviewed to determine if there were any documented internal control policies and procedures requiring the review and documentation of whether a vendor for goods and services which were being funded through federal award programs were either suspended or debarred from receiving or participating in federal awards. We were unable to find any documented internal control policies or procedures requiring a review for the suspension and debarment status of potential vendors for goods and services which were being funded through federal award programs. In addition, in relation to the project contracts entered into under the above noted major federal program a request was made for the backup documentation relating to the actual bid process that was followed such as copies of the request for bids, the bid specifications, the bids received and the actual approval of each bid. A request was also made relating to whether the bid process was waived for any of these project contracts and if such a waiver was made a copy of the meeting minutes of the Board of Selectmen of the Town approving such a waiver was requested. Part of the intent of requesting these bid related documents was to review the provided information to determine if any suspension and debarment review was made and documented. No information could be provided in relation to these requests. Questioned Costs: There are no questioned costs relating to this significant deficiency in internal control over compliance in relation to this procurement suspension and debarment finding. Context: The procurement suspension anddebarment compliance requirements relating to the above noted major federal programingeneral state that vendors who have been suspended or disbarred can not receive or participate in federal awards. We feel that not being able to provide some formof documentation showing that vendors for which goods or services were purchasedwith funds relating to the above noted major federal program were reviewed to determine if they were suspended or debarred from receiving or participating in federal awards indicates a significant deficiency in internal control over compliance in relation to the procurement suspension and debarment compliance requirement. Effect: During our review of the vendors being used in relation to the seven reported projects of the above noted major federal program, none were noted as being suspended or disbarred. However, the lack of adequate internal controls over these compliance requirements could provide an opportunity for noncompliance. Any funds found to have been paid to vendors who have been suspended or debarred from receiving or participating in federal awards could be required to be returned to the funding source. Cause: We were unable to determine why neither the provided bid ordinance or town charter included any internal controls relating to the review and documentation of the reviews of vendors in relation to their potential status of being suspended or disbarred from receiving or participating in federal awards. In addition, we did review certain contracts that were entered into in relation to the above noted major federal program and we were unable to find any references or clauses relating specifically to suspension and debarment. We were unable to determine why no references could be located within these reviewed contracts. Recommendation: We recommend that the Town more closely monitor vendors receiving and participating in federal award programs relating to procurement suspension anddebarment compliance requirements. In addition, we recommend that specific internal control policies and procedures be created, documented and implemented to ensure compliance in relation to all applicable procurement suspension and debarment requirements. Views of Responsible Officials: We have discussed this finding with our auditor and we do understand the importance of an adequate system of internal control policies and procedures relating to federal award program procurement suspension and debarment requirements. We do intend to review our bid ordinance and town charter, as time allows, to determine if any specific changes or modifications to these two documents should be made in relation to this compliance requirement.
2025-001 – Suspension and Debarment Cluster: Research and Development Grantor: Social Security Administration, National Science Foundation Award Name: Center for Retirement Research at Boston College and Affiliated Institutions: Retirement and Disability Research Consortium, Building a Youth-Led Learning Community through Automating Hydroponic Systems, Empowering Youth in STEM and Technological Careers through AI-Enhanced Sustainable and Community-Focused Urban Gardening Award Number: 6 RDR23000010, 2048994, 2241766 Award Year: FY2025 Assistance Listing Numbers: 96.007, 47.076, 47.076 Assistance Listing Titles: Social Security Research and Demonstration; STEM Education (formerly Education and Human Resources) Pass-Through Entities: None - Direct Criteria: Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the transaction. Condition: For 1 of 25 new vendors sampled, the vendor was not included in the ongoing suspension and debarment monitoring process, which is performed via a third-party servicer. Upon further discussion with the University, it was determined that the selected vendor was part of one day where a total of an additional 24 new vendors were also excluded from the ongoing process. Of the 25 total vendors, 3 of these vendors incurred expenditures related to federal awards totaling approximately $7,000 during the fiscal year. Cause: There was a system failure on one specific day between the University and the third-party servicer that prevented the suspension and debarment checks from being performed on new vendors. After the system failure, University personnel did not confirm that new vendors that were intended to be added on the date in question, were in fact added to the system. Effect: New vendors were not checked for suspension and debarment prior to the University entering into a transaction with the affected vendors. Questioned Costs: None noted. Repeat Finding: No. Recommendation: PwC recommends cross training of individuals responsible for the daily system interactions with the third-party servicer to ensure any system issues are promptly resolved and new vendors are checked for suspension and debarment prior to the University entering into a transaction with them. Management’s Views and Corrective Action Plan: Management’s response is included in Management's Views and Corrective Action Plan included at the end of this report after the Schedule of Status of Prior Audit Findings.
Congressional Grants – Suspension and Debarment: Information on Federal Program: U.S. Department of Housing and Urban Development Congressional Grant (Federal Assistance Listing Number 14.251). Criteria: 2 CFR Section 200.214 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the Organization is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The Organization did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214. Statement of Effect: The Organization is not in compliance with 2 CFR Section 200.214. The Organization is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the Organization could be overpaying for goods and services. Questioned Costs: None. Perspective Information: As part of the required procurement testing, a review of the vendor charged to the Congressional grant and therefore represented purchases with federal dollars was performed. The vendor was not suspended or debarred from participation in Federal assistance programs or activities. Recommendation: We recommend that the Organization review the requirements of 2 CFR Section 200.214 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of responsible officials and planned corrective actions: The Capital District YMCA reviewed the vendor used for our project when the auditors brought this to our attention and we did not find any suspension or disbarment information. We will incorporate this vendor review into our process for all programs or activities related to Federal contracts. This will be done in conjunction with the procurement policy and be in place by July 31, 2025.
Congressional Grants – Suspension and Debarment: Information on Federal Program: U.S. Department of Housing and Urban Development Congressional Grant (Federal Assistance Listing Number 14.251). Criteria: 2 CFR Section 200.214 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the Organization is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The Organization did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214. Statement of Effect: The Organization is not in compliance with 2 CFR Section 200.214. The Organization is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the Organization could be overpaying for goods and services. Questioned Costs: None. Perspective Information: As part of the required procurement testing, a review of the vendor charged to the Congressional grant and therefore represented purchases with federal dollars was performed. The vendor was not suspended or debarred from participation in Federal assistance programs or activities. Recommendation: We recommend that the Organization review the requirements of 2 CFR Section 200.214 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of responsible officials and planned corrective actions: The Capital District YMCA reviewed the vendor used for our project when the auditors brought this to our attention and we did not find any suspension or disbarment information. We will incorporate this vendor review into our process for all programs or activities related to Federal contracts. This will be done in conjunction with the procurement policy and be in place by July 31, 2025.
Federal Program: 93.493 – Congressional Directives, U.S. Department of Health and Human Services, FAIN CE152180 passed through the Health Resources & Services Administration Criteria or Specific Requirement: Procurement, Suspension & Debarment, 2 CFR 200.320 Condition: The Company paid funds to a vendor that qualified under sole source procurement requirements. In the vendor’s contract with the Company, the vendor confirmed it was not suspended or debarred. The Company did not document its process for determining sole source procurement or document its search to confirm the vendor was not suspended or debarred. Cause: The Company does not have policies in place that comply with federal procurement, suspension and debarment requirements. Effect: The Company’s internal controls did not ensure proper documentation that the vendor materially complied with the federal procurement requirements. Questioned Costs: None Context: Federal procurement standards require entities that receive federal awards to have specific policies that comply with 2 CFR Section 200.318-320. The requirements specify that policies must establish thresholds and procedures for micro-purchases, simplified acquisitions, and formal purchases. When vendors are selected, federal funds are prohibited from going to certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards (2 CFR 200.214). The Company did not have policies in place to ensure compliance with these federal procurement guidelines. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: The Company has policies for vendor qualification in place surrounding critical vendors. We recommend considering all vendors that are awarded contracts to be paid with federal awards critical or otherwise amending the Company’s contracting review process or critical vendor policy to incorporate specific procedures when federal funds are used. These procedures should include a documented search of Sam.gov for suspension and debarment of the vendor. The Company should establish procurement thresholds and specific procedures for those thresholds as outlined in 2 CFR Section 200.318-320. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See attached corrective action plan.
Criteria: In accordance with 2 CFR §180 and §200.214, non-federal entities are prohibited from entering into covered transactions with parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Entities must verify that contractors and subcontractors are not excluded by checking the System for Award Management (SAM.gov) prior to awarding contracts funded by federal awards. Condition and Context: During our audit of procurement activities under the Health Center Infrastructure Support federal award, we identified multiple instances where the entity failed to verify the suspension and debarment status of vendors prior to awarding contracts exceeding the $25,000 threshold. Documentation of verification through SAM.gov or equivalent methods was not available for these transactions. Subsequent review of SAM.gov indicated no instances of suspended or debarred vendors being used on the project funded with federal awards. Effect: Failure to verify vendor eligibility increases the risk of awarding federal funds to ineligible parties, which may result in questioned costs, reputational harm, and potential disallowance of expenditures by the federal awarding agency. Cause: While the Center’s formal policies dictate that procedures will be followed to ensure the above criteria are met, staff responsible for procurement were unaware of the verification requirement or did not consistently apply it. Recommendation: We recommend the entity ensure that staff involved with procuring contracts using federal awards are aware of the federal requirement, including the already-established policies that the Center has regarding such requirements. Staff involved in procurement should receive training on federal suspension and debarment requirements to ensure consistent compliance.
2025-004 Suspension and Debarment Program Information Federal Organizations U.S Department of Health and Human Services U.S Department of Agriculture (passed through California Department of Public Health) Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award Numbers H80CS00540-23, H8GCS48292, H8LCS51370, 22-10237 A05 Criteria Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transactions (procurement contracts, purchase orders, or agreements greater than or equal to $25,000) with persons or vendors. [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Condition The Organization entered into covered transactions without verification that vendors/contractors were not excluded from doing business with the federal government. This finding appears to be a systemic issue. Cause The Organization did not maintain documentation evidencing its compliance with its policy to verify that persons or entities contracted with were not listed on the exclusions list prior to entering into the contracts or purchase agreements. Effect The Organization may have entered into covered transactions with persons who have been suspended or debarred. Questioned Costs None noted. Context We tested four vendors with “covered transactions” under assistance listing numbers 93.224 and 93.527 and six under assistance listing number 10.557. All vendors selected were missing evidence of suspension and debarment checks being performed. However, we were able to independently verify that the vendors in question were not excluded through SAM.GOV. Recommendation We recommend the Organization perform vendor checks prior to entering into procurements meeting the covered transaction criteria, and retain documentation that the checks were performed and when they were performed. In addition, we recommend that the Organization update these checks on an annual basis. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.
2025-004 Lack of Documentation for SAM.gov Exclusion Checks. Type: Material Weakness. Condition: The Village did not retain documentation to support that exclusion checks were performed on SAM.gov for vendors and subrecipients associated with the Water and Waste Disposal Systems For Rural Communities program. As a result, there is no evidence that the entity verified whether these parties were suspended or debarred prior to entering covered transactions. Criteria: Per 2 CFR 180.300 and 200.214 of the Uniform Guidance, non-federal entities must verify that contractors and subrecipients are not suspended or debarred before awarding federal funds. Acceptable methods include: - Checking the SAM.gov exclusion list, - Collecting a certification from the entity, - Including a clause in the contract or agreement. - Documentation of the verification process must be retained to demonstrate compliance. Cause: The entity did not have a formal process in place to ensure that SAM.gov checks were performed and documented prior to awarding federal funds. Effect: Without documented verification, there is a risk that federal funds could be awarded to ineligible parties, potentially resulting in noncompliance with federal regulations and exposure to questioned costs or future audit findings. Questioned Costs: n/a. Recommendation: We recommend that the Village implement and enforce procedures to: - Perform SAM.gov exclusion checks prior to awarding federal funds, - Retain screenshots or other documentation as evidence of the checks, - Train relevant staff on compliance requirements under Uniform Guidance. Views of Responsible Officials: Management concurs with the auditor’s finding regarding the lack of verification against the System for Award Management (SAM.gov) prior to entering into agreements with subrecipients and contractors under federal awards. We acknowledge that conducting these checks is a critical control to ensure compliance with federal regulations and to prevent engagement with suspended or debarred entities. The omission was due to a gap in our internal procedures, and we are taking immediate corrective action. Management is implementing a formal policy requiring SAM.gov verification for all applicable transactions, and staff will be trained on the updated procedures. We are also exploring automated solutions to ensure consistent documentation and compliance moving forward. We appreciate the auditor’s observation and remain committed to strengthening our internal controls and ensuring full compliance with Uniform Guidance requirements.
2025-005 Suspension and Debarment Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684 Criteria [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transaction (procurement contracts, purchase orders or agreements greater than or equal to $25,000) with persons or vendors. Condition The Organization entered into covered transactions without verification that vendors/contractors were not excluded from doing business with the federal government. This finding appears to be a systemic problem Cause The Organization did not follow its policy to verify that persons or entities contracted with were not listed on the exclusions list prior to entering into the contracts or purchase agreements. Effect The Organization may have entered into covered transactions with persons who have been suspended or debarred. Questioned Costs None noted. Context Out of four covered transactions selected, only one included evidence that an exclusion check was performed prior to signing the contract. Exclusions checks were performed after documentation was requested by the auditor and no excluded vendors were identified. Recommendation We recommend the Organization implement controls requiring that exclusion checks be performed prior to signing any contracts or purchase orders or agreements that are covered transactions. This exclusion check should be maintained as part of the supporting documentation for the expenditure. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.
2025-005 Suspension and Debarment Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684 Criteria [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transaction (procurement contracts, purchase orders or agreements greater than or equal to $25,000) with persons or vendors. Condition The Organization entered into covered transactions without verification that vendors/contractors were not excluded from doing business with the federal government. This finding appears to be a systemic problem Cause The Organization did not follow its policy to verify that persons or entities contracted with were not listed on the exclusions list prior to entering into the contracts or purchase agreements. Effect The Organization may have entered into covered transactions with persons who have been suspended or debarred. Questioned Costs None noted. Context Out of four covered transactions selected, only one included evidence that an exclusion check was performed prior to signing the contract. Exclusions checks were performed after documentation was requested by the auditor and no excluded vendors were identified. Recommendation We recommend the Organization implement controls requiring that exclusion checks be performed prior to signing any contracts or purchase orders or agreements that are covered transactions. This exclusion check should be maintained as part of the supporting documentation for the expenditure. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.
Finding 2024-001: Suspension and Debarment (Significant Deficiency) Information on the Federal Program: 93.048 Criteria: According to 2 CFR §200.30, the non-Federal entity (i.e. the Organization) must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and 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 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 Organization failed to perform and/or properly document its due diligence with respect to these requirements. Cause: The Organization experienced turnover during the year, resulting in inconsistency and oversight of the compliance requirement. Effect or Potential Effect: The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. If a non-Federal entity knowingly does business with an excluded person, the agency responsible for the Center's funding may disallow costs, annul or terminate the transaction, issue a stop work order, debar or suspend the non-Federal entity, or take other remedies as appropriate. Questioned Costs: None noted. Context: During our audit, we noted two cases our of nine samples in which the Organization did not perform or did not maintain proper support to demonstrate that it performed 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. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend the Organization 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 of any current vendors, contractors, or consultants as well.
Procurement, Suspension and Debarment Federal agency: U.S. Department of Health and Human Services Program: Continuation of the National Evaluations System for Health Technology Coordinating Center Assistance listing number: 93.103 Federal award identification number and year: • 2U01FD006292-06 2024 • 3U01FD006292-06S1 2023 Criteria: 2 CFR 200.318 states non-federal entities must have and use documented procurement procedures that conform to 2 CFR 200.317 through 200.327. 2 CFR 200.214 states non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Order 12549 and 12689, 2 CFR Part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 200 requires adequate documentation of compliance with 2 CFR 200.214. Condition and context: The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed however the evidence of the search on sam.gov was not retained. A sample of five vendors with a total contract value of $8,528,526 was selected from a population of twelve. Cause: The Organization’s management did not retain evidence of compliance with the above criteria regarding suspension and debarment due to oversight. Effect: The Organization’s documentation was lacking evidence of tracking vendors for suspension and debarment. Questioned costs: None Repeat finding: No Recommendation: We recommend management updates its policies and procedures to ensure adequate supporting documentation of suspension and debarment verification is maintained. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Procurement, Suspension and Debarment Federal agency: U.S. Department of Health and Human Services Program: Continuation of the National Evaluations System for Health Technology Coordinating Center Assistance listing number: 93.103 Federal award identification number and year: • 2U01FD006292-06 2024 • 3U01FD006292-06S1 2023 Criteria: 2 CFR 200.318 states non-federal entities must have and use documented procurement procedures that conform to 2 CFR 200.317 through 200.327. 2 CFR 200.214 states non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Order 12549 and 12689, 2 CFR Part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 200 requires adequate documentation of compliance with 2 CFR 200.214. Condition and context: The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed however the evidence of the search on sam.gov was not retained. A sample of five vendors with a total contract value of $8,528,526 was selected from a population of twelve. Cause: The Organization’s management did not retain evidence of compliance with the above criteria regarding suspension and debarment due to oversight. Effect: The Organization’s documentation was lacking evidence of tracking vendors for suspension and debarment. Questioned costs: None Repeat finding: No Recommendation: We recommend management updates its policies and procedures to ensure adequate supporting documentation of suspension and debarment verification is maintained. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.
Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds ALN 20.205, Department of Transportation, Highway Planning and Construction Federal Award Identification Number and Year ALN 21.027: 1505 0271, 2022 ALN 20.205: 24455, 2021 Pass through Entity ALN 21.027: Not applicable ALN 20.205: Colorado Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Nonfederal entities may satisfy the criteria prescribed by 2 CFR part 180 by either checking SAM.gov exclusions, collecting a certification or adding a clause or condition to the covered transaction with the contracted party. Condition The Town could not provide evidence that it performed a check to verify its contractors were not suspended or debarred. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Town used each of its grants to procure services from one contractor and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into its contracts, respectively. Plante & Moran, PLLC reviewed the SAM.gov website, noting that the two vendors were not listed as suspended or disbarred. Cause and Effect The Town did not retain evidence to support that it had conducted the search for whether the contractors were suspended or debarred prior to entering into the contracts. The lack of control could result in the Town entering into contracts with contractors that are suspended or debarred. Subsequently, the Town did complete the search on SAM.gov and retained evidence to support that the contractors were not suspended of debarred, thereby creating no questioned costs. Recommendation We recommend the Town implement its controls as designed by retaining supporting documentation to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The Town acknowledges the finding. The oversight was unintentional and occurred due to a lack of formalized procedures for verifying suspension and debarment status for all applicable federal contracts and subawards.
Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds ALN 20.205, Department of Transportation, Highway Planning and Construction Federal Award Identification Number and Year ALN 21.027: 1505 0271, 2022 ALN 20.205: 24455, 2021 Pass through Entity ALN 21.027: Not applicable ALN 20.205: Colorado Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Nonfederal entities may satisfy the criteria prescribed by 2 CFR part 180 by either checking SAM.gov exclusions, collecting a certification or adding a clause or condition to the covered transaction with the contracted party. Condition The Town could not provide evidence that it performed a check to verify its contractors were not suspended or debarred. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Town used each of its grants to procure services from one contractor and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into its contracts, respectively. Plante & Moran, PLLC reviewed the SAM.gov website, noting that the two vendors were not listed as suspended or disbarred. Cause and Effect The Town did not retain evidence to support that it had conducted the search for whether the contractors were suspended or debarred prior to entering into the contracts. The lack of control could result in the Town entering into contracts with contractors that are suspended or debarred. Subsequently, the Town did complete the search on SAM.gov and retained evidence to support that the contractors were not suspended of debarred, thereby creating no questioned costs. Recommendation We recommend the Town implement its controls as designed by retaining supporting documentation to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The Town acknowledges the finding. The oversight was unintentional and occurred due to a lack of formalized procedures for verifying suspension and debarment status for all applicable federal contracts and subawards.
Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds ALN 20.205, Department of Transportation, Highway Planning and Construction Federal Award Identification Number and Year ALN 21.027: 1505 0271, 2022 ALN 20.205: 24455, 2021 Pass through Entity ALN 21.027: Not applicable ALN 20.205: Colorado Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Nonfederal entities may satisfy the criteria prescribed by 2 CFR part 180 by either checking SAM.gov exclusions, collecting a certification or adding a clause or condition to the covered transaction with the contracted party. Condition The Town could not provide evidence that it performed a check to verify its contractors were not suspended or debarred. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Town used each of its grants to procure services from one contractor and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into its contracts, respectively. Plante & Moran, PLLC reviewed the SAM.gov website, noting that the two vendors were not listed as suspended or disbarred. Cause and Effect The Town did not retain evidence to support that it had conducted the search for whether the contractors were suspended or debarred prior to entering into the contracts. The lack of control could result in the Town entering into contracts with contractors that are suspended or debarred. Subsequently, the Town did complete the search on SAM.gov and retained evidence to support that the contractors were not suspended of debarred, thereby creating no questioned costs. Recommendation We recommend the Town implement its controls as designed by retaining supporting documentation to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The Town acknowledges the finding. The oversight was unintentional and occurred due to a lack of formalized procedures for verifying suspension and debarment status for all applicable federal contracts and subawards.
2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.
2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.
2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.
2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.
2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.
Criteria or Specific Requirement – Per 2 CFR §180.300 and §200.214, non-federal entities are prohibited from entering into covered transactions (e.g., contracts or subawards expected to equal or exceed $25,000) with parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Conditions – Verification of SAMS.gov vendors was not performed. Context – During our testing of procurement, we sampled nine expenditures totaling $367,163. The total population of procurement expenditures charged to the program was $800,000. We noted that all nine selections of expenditures did not have SAMS.gov verification documentation. Cause – The Association did not have a formal process or checklist to ensure that vendors were checked against the SAM.gov exclusion list before contract award. Procurement staff were not trained on this requirement. Effect – Use of non-approved vendors could have occurred. However, as part our audit procedures, we determined that the expenditures were made with contractors which were not suspended or disbarred and were approved on the SAMS.gov website. Recommendation – We recommend the Association implement a formal policy and procedure to verify all vendors against SAM.gov for covered transactions exceeding $25,000. Staff responsible for federal procurement should be trained, and documentation of vendor status verification should be retained with procurement records. Views of Responsible Officials and Planned Corrective Actions – Procurement Policy was updated and documentation will be maintained to support vendor verification in the future.
Subject: 2024-002 Material Weakness – Procurement and Suspension and Debarment Noncompliance Federal Agency: Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness – Procurement and Suspension and Debarment Noncompliance Criteria: In accordance with 2 CFR §200.214 and 2 CFR Part 180, the City is required to ensure that it does not enter into a covered transaction with a party that is suspended or debarred. Verification must be performed through one of the following: checking SAM.gov, collecting a certification, or adding a contract clause requiring compliance. Federal Award Findings and Questioned Costs (Continued) Condition and Context: The City lacked a formalized procedure for verifying suspension and debarment status for 1 covered transaction under revenue loss category for the CSLFRF award. This covered transaction paid for additional costs added onto the purchase of a fire engine with a change order related to increased manufacturing costs incurred as a result of the Coronavirus pandemic. The City did not verify suspension and debarment on this vendor prior to paying for these costs under CSLFRF. Without proper verification, the City risks using federal funds to engage with ineligible vendors, which could result in questioned costs, repayment obligations to the federal government, or future audit findings that may impact continued federal funding. Although no suspended or debarred vendors were identified in the sampled transactions, the lack of internal controls and documentation constitutes material noncompliance with 2 CFR §200.214. Cause and Effect: The City did not establish formal procedures on suspension and debarment requirements for one of the eleven covered transactions tested, resulting in material noncompliance with the suspension and debarment requirements of the CSLRF program and increased risk of using federal funds with ineligible vendors. Recommendation: We recommend the City develop and implement formal written procedures to ensure suspension and debarment checks are performed on all CSLFRF transactions and documented appropriately. Views of Responsible Officials and Planned Corrective Actions: The City agrees with the recommendation and plans to implement corrective action by December 31, 2025. Staff are in the process of drafting internal policies for adoption by the appropriate boards to address this item as soon as possible for any of our grant funds not managed by a third-party administrator.
Criteria or Specific Requirements Per 2 CFR 200.214 Suspension and debarment, non-Federal entities are subject to the nonprocurement 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 excluded from or ineligible for participation in Federal assistance programs or activities. Per CFR 180.300, Subpart C: Responsibilities of Participants Regarding Transactions Doing Business With Other Persons, when an entity enters into a covered transaction with another person at the next lower tier, the entity must verify that the person with whom the entity intends to do business is not excluded or disqualified. The entity does this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-002. Per the CAP, the Foundation will conduct regular, ongoing monitoring of vendors providing services billed to grantors, including identifying all grant-reimbursed vendors and coordinating with Accounts Payable to perform annual suspension and debarment checks. We noted that the Foundation’s updated formal policies and procedures now require suspension and debarment checks at initial vendor setup and on an annual basis thereafter. Based on test work over a sample of 6 vendors covering the period from September 1, 2024 (CAP implementation date) to December 31, 2024, we did not identify any vendors in the sample who were suspended or debarred. However, we were unable to obtain documentation demonstrating that the Foundation performed the annual vendor suspension and debarment verification checks. Evidence that the annual vendor suspension and debarment verification checks had been performed was not yet available. Questioned Costs None. Cause and Effect For the period from September 1, 2024 (CAP implementation date) to December 31, 2024, the annual vendor suspension and debarment verification checks were still in progress, and supporting documentation was not yet available. The Foundation subsequently completed the annual checks in February 2025, which aligns with the typical start dates of most vendor contracts.
Criteria or Specific Requirements Per 2 CFR 200.214 Suspension and debarment, non-Federal entities are subject to the nonprocurement 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 excluded from or ineligible for participation in Federal assistance programs or activities. Per CFR 180.300, Subpart C: Responsibilities of Participants Regarding Transactions Doing Business With Other Persons, when an entity enters into a covered transaction with another person at the next lower tier, the entity must verify that the person with whom the entity intends to do business is not excluded or disqualified. The entity does this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-002. Per the CAP, the Foundation will conduct regular, ongoing monitoring of vendors providing services billed to grantors, including identifying all grant-reimbursed vendors and coordinating with Accounts Payable to perform annual suspension and debarment checks. We noted that the Foundation’s updated formal policies and procedures now require suspension and debarment checks at initial vendor setup and on an annual basis thereafter. Based on test work over a sample of 6 vendors covering the period from September 1, 2024 (CAP implementation date) to December 31, 2024, we did not identify any vendors in the sample who were suspended or debarred. However, we were unable to obtain documentation demonstrating that the Foundation performed the annual vendor suspension and debarment verification checks. Evidence that the annual vendor suspension and debarment verification checks had been performed was not yet available. Questioned Costs None. Cause and Effect For the period from September 1, 2024 (CAP implementation date) to December 31, 2024, the annual vendor suspension and debarment verification checks were still in progress, and supporting documentation was not yet available. The Foundation subsequently completed the annual checks in February 2025, which aligns with the typical start dates of most vendor contracts.
Criteria or Specific Requirements Per 2 CFR 200.214 Suspension and debarment, non-Federal entities are subject to the nonprocurement 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 excluded from or ineligible for participation in Federal assistance programs or activities. Per CFR 180.300, Subpart C: Responsibilities of Participants Regarding Transactions Doing Business With Other Persons, when an entity enters into a covered transaction with another person at the next lower tier, the entity must verify that the person with whom the entity intends to do business is not excluded or disqualified. The entity does this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-002. Per the CAP, the Foundation will conduct regular, ongoing monitoring of vendors providing services billed to grantors, including identifying all grant-reimbursed vendors and coordinating with Accounts Payable to perform annual suspension and debarment checks. We noted that the Foundation’s updated formal policies and procedures now require suspension and debarment checks at initial vendor setup and on an annual basis thereafter. Based on test work over a sample of 6 vendors covering the period from September 1, 2024 (CAP implementation date) to December 31, 2024, we did not identify any vendors in the sample who were suspended or debarred. However, we were unable to obtain documentation demonstrating that the Foundation performed the annual vendor suspension and debarment verification checks. Evidence that the annual vendor suspension and debarment verification checks had been performed was not yet available. Questioned Costs None. Cause and Effect For the period from September 1, 2024 (CAP implementation date) to December 31, 2024, the annual vendor suspension and debarment verification checks were still in progress, and supporting documentation was not yet available. The Foundation subsequently completed the annual checks in February 2025, which aligns with the typical start dates of most vendor contracts.
Criteria or Specific Requirements Per 2 CFR 200.214 Suspension and debarment, non-Federal entities are subject to the nonprocurement 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 excluded from or ineligible for participation in Federal assistance programs or activities. Per CFR 180.300, Subpart C: Responsibilities of Participants Regarding Transactions Doing Business With Other Persons, when an entity enters into a covered transaction with another person at the next lower tier, the entity must verify that the person with whom the entity intends to do business is not excluded or disqualified. The entity does this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-002. Per the CAP, the Foundation will conduct regular, ongoing monitoring of vendors providing services billed to grantors, including identifying all grant-reimbursed vendors and coordinating with Accounts Payable to perform annual suspension and debarment checks. We noted that the Foundation’s updated formal policies and procedures now require suspension and debarment checks at initial vendor setup and on an annual basis thereafter. Based on test work over a sample of 6 vendors covering the period from September 1, 2024 (CAP implementation date) to December 31, 2024, we did not identify any vendors in the sample who were suspended or debarred. However, we were unable to obtain documentation demonstrating that the Foundation performed the annual vendor suspension and debarment verification checks. Evidence that the annual vendor suspension and debarment verification checks had been performed was not yet available. Questioned Costs None. Cause and Effect For the period from September 1, 2024 (CAP implementation date) to December 31, 2024, the annual vendor suspension and debarment verification checks were still in progress, and supporting documentation was not yet available. The Foundation subsequently completed the annual checks in February 2025, which aligns with the typical start dates of most vendor contracts.
Criteria or Specific Requirements Per 2 CFR 200.214 Suspension and debarment, non-Federal entities are subject to the nonprocurement 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 excluded from or ineligible for participation in Federal assistance programs or activities. Per CFR 180.300, Subpart C: Responsibilities of Participants Regarding Transactions Doing Business With Other Persons, when an entity enters into a covered transaction with another person at the next lower tier, the entity must verify that the person with whom the entity intends to do business is not excluded or disqualified. The entity does this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-002. Per the CAP, the Foundation will conduct regular, ongoing monitoring of vendors providing services billed to grantors, including identifying all grant-reimbursed vendors and coordinating with Accounts Payable to perform annual suspension and debarment checks. We noted that the Foundation’s updated formal policies and procedures now require suspension and debarment checks at initial vendor setup and on an annual basis thereafter. Based on test work over a sample of 6 vendors covering the period from September 1, 2024 (CAP implementation date) to December 31, 2024, we did not identify any vendors in the sample who were suspended or debarred. However, we were unable to obtain documentation demonstrating that the Foundation performed the annual vendor suspension and debarment verification checks. Evidence that the annual vendor suspension and debarment verification checks had been performed was not yet available. Questioned Costs None. Cause and Effect For the period from September 1, 2024 (CAP implementation date) to December 31, 2024, the annual vendor suspension and debarment verification checks were still in progress, and supporting documentation was not yet available. The Foundation subsequently completed the annual checks in February 2025, which aligns with the typical start dates of most vendor contracts.
Criteria or Specific Requirements Per 2 CFR 200.214 Suspension and debarment, non-Federal entities are subject to the nonprocurement 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 excluded from or ineligible for participation in Federal assistance programs or activities. Per CFR 180.300, Subpart C: Responsibilities of Participants Regarding Transactions Doing Business With Other Persons, when an entity enters into a covered transaction with another person at the next lower tier, the entity must verify that the person with whom the entity intends to do business is not excluded or disqualified. The entity does this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-002. Per the CAP, the Foundation will conduct regular, ongoing monitoring of vendors providing services billed to grantors, including identifying all grant-reimbursed vendors and coordinating with Accounts Payable to perform annual suspension and debarment checks. We noted that the Foundation’s updated formal policies and procedures now require suspension and debarment checks at initial vendor setup and on an annual basis thereafter. Based on test work over a sample of 6 vendors covering the period from September 1, 2024 (CAP implementation date) to December 31, 2024, we did not identify any vendors in the sample who were suspended or debarred. However, we were unable to obtain documentation demonstrating that the Foundation performed the annual vendor suspension and debarment verification checks. Evidence that the annual vendor suspension and debarment verification checks had been performed was not yet available. Questioned Costs None. Cause and Effect For the period from September 1, 2024 (CAP implementation date) to December 31, 2024, the annual vendor suspension and debarment verification checks were still in progress, and supporting documentation was not yet available. The Foundation subsequently completed the annual checks in February 2025, which aligns with the typical start dates of most vendor contracts.
Criteria or Specific Requirements Per 2 CFR 200.214 Suspension and debarment, non-Federal entities are subject to the nonprocurement 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 excluded from or ineligible for participation in Federal assistance programs or activities. Per CFR 180.300, Subpart C: Responsibilities of Participants Regarding Transactions Doing Business With Other Persons, when an entity enters into a covered transaction with another person at the next lower tier, the entity must verify that the person with whom the entity intends to do business is not excluded or disqualified. The entity does this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-002. Per the CAP, the Foundation will conduct regular, ongoing monitoring of vendors providing services billed to grantors, including identifying all grant-reimbursed vendors and coordinating with Accounts Payable to perform annual suspension and debarment checks. We noted that the Foundation’s updated formal policies and procedures now require suspension and debarment checks at initial vendor setup and on an annual basis thereafter. Based on test work over a sample of 6 vendors covering the period from September 1, 2024 (CAP implementation date) to December 31, 2024, we did not identify any vendors in the sample who were suspended or debarred. However, we were unable to obtain documentation demonstrating that the Foundation performed the annual vendor suspension and debarment verification checks. Evidence that the annual vendor suspension and debarment verification checks had been performed was not yet available. Questioned Costs None. Cause and Effect For the period from September 1, 2024 (CAP implementation date) to December 31, 2024, the annual vendor suspension and debarment verification checks were still in progress, and supporting documentation was not yet available. The Foundation subsequently completed the annual checks in February 2025, which aligns with the typical start dates of most vendor contracts.