Finding Text
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
2 CFR §180.300 mandates that 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 is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition and Context
The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System.
Cause and Effect
The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties.
Questioned Costs
N/A
Identification of Repeat Findings
2022-012
Recommendation
We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.