Finding Text
Finding 2023-005: Suspension and Debarment (Significant Deficiency)
Information on the Federal Program: ALN 19.663 Global Telecommunications and Emerging
Technology Training
Criteria: Under 2 CFR §200.213, non-Federal entities are subject to the non-procurement debarment
and suspension regulations included in Executive Orders 12549 and 12689 and 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; or (b) Collecting a certification from that
person; or (c) Adding a clause or condition to the covered transaction with that person.
Condition: During our testing over Suspension and Debarment, we determined that USTTI did not
perform screenings on potential or current vendors, suppliers or contractors that were paid with
Federal funds.
Cause: USTTI does not have a formal internal policy with respect to screening vendors, suppliers,
contractors and employees in order to adhere to compliance over suspension and debarment.
Effect: Failure to screen potential and current vendors, suppliers, contractors and employees
increases the potential that Federal funds be inadvertently provided to parties deemed to be
suspended or disbarred by the United States Government.
Questioned Costs: None.
Context: We noted that none of the vendors, suppliers etc. selected for testing had a formally
documented Suspension and Debarment check conducted prior to payment of their invoices.Context (Continued): Due to the timing of the audit for the year ended December 31, 2022, USTTI
was not able to formalize a policy for the year ended December 31, 2023. We noted that USTTI has
formalized a suspension and debarment policy during the year ended December 31, 2024.
Identification as a Repeat Finding: Yes. See Finding 2022-04.
Recommendation: We recommend that management develop and implement a formal policy on
suspension and debarment. This policy should include a threshold for when vendors, suppliers,
contractors and employees should be screened. All screenings should be conducted prior to signing a
contract or issuing payment. We recommend that USTTI notify all employees of this policy and ensure
that it is enforced during the upcoming fiscal year.