Criteria: The Foundation is responsible for implementing policies, including internal controls, that are designed to provide reasonable assurance regarding the achievement of the following objectives: effectiveness and efficiency of operations, reliability of reporting for internal and external use; and compliance with applicable laws and regulations. Per 2 CFR 180.300 and 200.318-200.326, the Foundation is responsible for implementing policies and procedures before entering into covered transactions with vendors as well as performing competitive bidding procedures for vendors used in federal award spending. Condition: The overall process for tracking federal funds spent and the reimbursement process is a manual process performed by one department. For majority of the year the Foundation lacked formal policies for reimbursement, procurement and timely review of calculations throughout the year. Cause: The Foundation saw increased levels of federal funding during the previous year and did not have the process in place to ensure compliance until majority of the way through the year. Effect: The lack of process documentation and review process limited the Foundation’s ability to design and implement the necessary internal controls over compliance with federal awards. Questioned Costs: Indeterminable. Context: The finding represents a systematic deficiency in the Foundation’s process surrounding federal funds. This finding cannot be quantified in terms of dollar value. Repeat Finding: This is partially a repeat finding as the Foundation implemented the required policies during the year ended December 31, 2024. Recommendation: We recommend increased training in federal grant compliance and specific grant requirements. Additionally, the Foundation should continue to review and implement formal processes surrounding federal funds and the review of reimbursement requests. Views of Responsible Officials: Management concurs with the finding and implemented a comprehensive procurement policy in October 2024 compliant with federal regulations under the Uniform Guidance (2 CFR Part 200), with full staff training completed and internal monitoring controls established.
2024-001: Internal Controls over Compliance for Procurement Suspension & Debarment U.S. DEPARTMENT OF TREASURY COVID-19 Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027 Criteria: Per 2 CFR sections 200.318 through 200.327, [entities] must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Further, 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. Condition: The City did not follow its Grant Standard Operating procedures for validating that a contractor was not suspended or debarred or otherwise excluded from participating in the transaction. Cause: The contract agreement was finalized without validation that all proper procurement procedures had been followed. Effect: By not following the City’s procedures in place, it puts the City at risk of doing business with companies who are suspended, debarred or otherwise excluded from doing business with the federal government. Questioned Costs: $0 Context: The auditor tested one procurement transaction entered into during 2024 using COVID- 19 Coronavirus State and Local Fiscal Recovery Funds. The City’s Grant Standard Operating procedures over suspension and debarment were not followed for this one procurement. Identification of Repeat Finding: Not a repeat finding. Recommendation: We recommend the City perform a separate individual check of contract files to ensure the City’s Grant Standard Operating procedures are followed and documented prior to entering into a contract agreement with covered contractors. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and is in the process of developing internal controls to ensure timely and appropriate actions are taken on the deficiency noted. Additional details can be found in the City of Bloomington’s Corrective Action Plan.
2024-003: Lack of Procurement Policy – Significant Deficiency AL 66.468 Base Capitalization Grants for Drinking Water State Revolving Funds Criteria 2 CFR Part 200.318 states that a non-Federal entity must have and use documented procedures, consistent with state, local, and tribal laws and regulations and the standards of 2 CFR part 200.317 through 200.327. Condition The City does not have a written procurement policy in place. Cause The City has not written and approved a procurement policy. Effect Non-compliance with Procurement Suspension & Debarment compliance requirements. Questioned Costs $0 Recommendation We recommend for the City to create and implement a procurement policy that adheres to state and local regulations as well as 2 CFR Part 200.317 through 200.327. Views of Responsible Officials A procurement policy will be developed and approved by the City Council. Repeat Finding This is a new finding.
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 Uniform Guidance requires non-federal entities to follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. The Organization is required to adopt and maintain a written procurement policy in accordance with Uniform Guidance procurement standards and perform and document suspended and debarment searches for potential vendors prior to procuring services from the contractor. If bids are not obtained in accordance with the Organization’s procurement procedures due to using the noncompetitive procurement method, documentation must be prepared and retained including justification for sole-source procurement. Condition and Context The Organization does not have a documented procurement policy in accordance with 2 CFR Part 200. We noted four contractors that had total 2024 purchases over $10,000 and selected two for testing. We noted the following deficiencies in our testing: - For the two contractors tested, the Organization had no documentation to support that its suspension and debarment verification procedures were performed prior to procuring services from contractors. Therefore, we have concluded that such verifications were not timely performed. - The two contractors tested were selected using the noncompetitive procurement method. When the Organization relied on sole-source justification to procure services, the Organization did not document its sole-source justification prior to procuring services from the contractor. Cause The Organization assumed that following the procurement standards in 2 CFR Part 200 was a sufficient procurement policy and the Organization was not aware that a documented procurement policy in accordance with 2 CFR Part 200 was required. Further, the Organization was not aware of the necessity to document its suspension and debarment search procedures and justification for sole-source procurements prior to procuring services from contractors. Effect Without a formal procurement policy, or abidance of the documentation requirements of 2 CFR Part 200, there is an increased risk that procurement activities may not be conducted in compliance with federal requirements, potentially leading to unallowable costs or questioned costs. Questioned Cost: None due to auditor agreeing with verbal justification of sole-source procurements. Recommendation We recommend that management develop and implement a formal procurement policy that aligns with the requirements of the Uniform Guidance. We recommend that management ensure all procurement policy requirements are performed and documented prior to entering into procurement transactions. Views of Responsible Officials and Planned Corrective Actions See Correction Action Plan.
Criteria Uniform Guidance requires non-federal entities to follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. The Organization is required to adopt and maintain a written procurement policy in accordance with Uniform Guidance procurement standards and perform and document suspended and debarment searches for potential vendors prior to procuring services from the contractor. If bids are not obtained in accordance with the Organization’s procurement procedures due to using the noncompetitive procurement method, documentation must be prepared and retained including justification for sole-source procurement. Condition and Context The Organization does not have a documented procurement policy in accordance with 2 CFR Part 200. We noted four contractors that had total 2024 purchases over $10,000 and selected two for testing. We noted the following deficiencies in our testing: - For the two contractors tested, the Organization had no documentation to support that its suspension and debarment verification procedures were performed prior to procuring services from contractors. Therefore, we have concluded that such verifications were not timely performed. - The two contractors tested were selected using the noncompetitive procurement method. When the Organization relied on sole-source justification to procure services, the Organization did not document its sole-source justification prior to procuring services from the contractor. Cause The Organization assumed that following the procurement standards in 2 CFR Part 200 was a sufficient procurement policy and the Organization was not aware that a documented procurement policy in accordance with 2 CFR Part 200 was required. Further, the Organization was not aware of the necessity to document its suspension and debarment search procedures and justification for sole-source procurements prior to procuring services from contractors. Effect Without a formal procurement policy, or abidance of the documentation requirements of 2 CFR Part 200, there is an increased risk that procurement activities may not be conducted in compliance with federal requirements, potentially leading to unallowable costs or questioned costs. Questioned Cost: None due to auditor agreeing with verbal justification of sole-source procurements. Recommendation We recommend that management develop and implement a formal procurement policy that aligns with the requirements of the Uniform Guidance. We recommend that management ensure all procurement policy requirements are performed and documented prior to entering into procurement transactions. Views of Responsible Officials and Planned Corrective Actions See Correction Action Plan.
Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 State Agency: Wisconsin Department Workforce Development State Number(s): Not applicable Award Period: December 14, 2021 – June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance and Noncompliance Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred. The Organization should be updated to reflect all procurement policy requirements outlined by Uniform Guidance. Additionally, the Organization should implement policies to ensure it is not entering into a covered transaction with an entity that has been suspended or debarred, as defined in 2 CFR section 180.995. Condition: Procurement and suspension and debarment policies are not in compliance with Uniform Guidance. Therefore, the Organization did not have procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. However, per review of SAM.gov during audit testing, it was determined that no tested vendors were suspended nor debarred. Questioned costs: None Context: CLA completed procurement and suspension and debarment testing and it was noted that the Organization's related policies were not in accordance with Uniform Guidance. Additionally, CLA tested suspension and debarment procedures over the sole covered transaction to determine whether the Organization complied with the requirements for charging costs to grants passed through the Wisconsin Department of Workforce Development. There was no documentation to show that a suspension and debarment check was performed prior to entering into the covered transaction, however the Organization did perform a check via SAM.gov at a subsequent date and determined the contractor was not suspended nor debarred. Cause: The Organization was not aware of policy and documentation requirements under Uniform Guidance for procurement and suspension and debarment. Effect: Noncompliant policies can lead to selecting vendors that are suspended and debarred and could result in the procurement of goods and services that are unideal for programs. When not approved by the granting agency, not following suspension and debarment procedures is considered a form of noncompliance with the grant provision. Repeat Finding: No Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized purchasers within the Organization, including verifying that suspension and debarment checks are performed and documented prior to entering into covered transactions. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.