Finding Text
Criteria:
The requirements for non-procurement suspension and debarment are contained in OMB guidance in 2 CFR Part
180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension;” federal awarding agency
regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation;
and the terms and conditions of the award.
Condition:
The Organization had covered transactions for goods and services that exceeded $25,000 during the year. Prior to
entering into the covered transactions, the Organization did not verify that the service provider was not suspended,
debarred, or otherwise excluded by the Federal Government.
Context:
The Organization made payments to four vendors for services and goods in excess of $25,000, per vendor, during
the period of the audit. Per our testing, the Organization did not have documentation showing that prior to entering
into transactions with the vendors the Organization verified that the vendors were not suspended or disbarred by
the Federal Government. As part of our testing, we verified that all four vendors were not suspended or disbarred.
Cause:
The Organization did not have a process in place to identify covered transactions or verify that entities providing
goods or services are not suspended or debarred.
Effect:
The Organization entered into covered transactions without knowing if the entity was suspended or disbarred from
the transaction.
Recommendation:
We recommend that the Organization implement the established written policy that identifies when the
Organization enters a covered transaction and the necessary steps to take prior to entering into a covered
transaction to verify that an entity is not suspended or disbarred and complete the required Contractor Debarment
Certification Form for all covered transactions.
Management’s Response:
Management agrees.