Finding 1074776 (2023-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-26
Audit: 321069
Organization: Farmworker Justice (DC)

AI Summary

  • Core Issue: The Organization failed to document vendor checks for suspension and debarment before making payments.
  • Impacted Requirements: This violates 2 CFR Section 200.214, which mandates verification against the SAM website for covered transactions.
  • Recommended Follow-Up: Implement internal controls to ensure proper documentation of SAM checks is maintained prior to vendor payments.

Finding Text

Finding 2023-003: Procurement, Suspension, and Debarment (Significant Deficiency) Federal Program: 93.129 - U.S. Department of Health and Human Services Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions, a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded. This verification may be accomplished by checking the System for Award Management (SAM) website maintained by the General Services Administration. Condition: For all disbursements tested, the Organization could not provide documentation of their verification, prior to payment, that the vendors were not suspended, debarred or otherwise excluded. Questioned Costs: NoneCause: The Organization required evidence of SAM checks be maintained in its vendor files after conclusion of the 2022 audit, which was completed in October 2023. As a result, the Organization did not maintain adequate support to provide evidence that appropriate suspension and debarment searches were performed for all 2023 transactions. However, SAM checks were performed after the fact to verify that the vendors or individuals in our sample were not suspended, debarred or otherwise excluded. Therefore, no questioned costs have been reported related to the sample that was tested. Effect or Potential Effect: The Organization was not in compliance with the procurement documentation requirements of the Uniform Guidance. As a result, the Organization could not readily provide evidence that it had assessed whether or not its vendors were suspended, debarred, or otherwise excluded. The potential for payments to suspended, debarred, or otherwise excluded vendors and individuals exists. Recommendation: The Organization should establish internal controls to ensure proper documentation is maintained as evidence to support that the Organization performed the required suspension and debarment searches on the SAM website. Repeat Finding: Yes. See Finding 2022-002.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 498333 2023-002
    Significant Deficiency
  • 498334 2023-003
    Significant Deficiency Repeat
  • 498335 2023-002
    Significant Deficiency
  • 498336 2023-003
    Significant Deficiency Repeat
  • 1074775 2023-002
    Significant Deficiency
  • 1074777 2023-002
    Significant Deficiency
  • 1074778 2023-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
17.700 Women's Bureau $198,936
17.502 Occupational Safety and Health Susan Harwood Training Grants $64,391
93.129 Technical and Non-Financial Assistance to Health Centers $47,023