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.