Finding 1089678 (2023-002)

Finding 2023-002: Information on the Federal Programs: 1) Assistance Listing Number 11.431 - Climate and Atmospheric Research, United States Department of Commerce. Award Number: NA20OAR4310366. Compliance Requirements: Procurement and Suspension and Debarment. Type of Finding: Significant Deficiency. 2) Assistance Listing Number 15.246 - Threatened and Endangered Species, United States Department of the Interior. Award Number: L21AC10475-02. Compliance Requirements: Procurement and Suspension and Debarment. Type of Finding: Significant Deficiency. Criteria: Program requirements state that the Organization was required to comply with requirements related to debarment and suspension. Condition: We noted written policies were in place to verify that an entity with which the Organization plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, however the Organization was unable to provide evidence that certain procedures described in these policies were being followed. Cause: The Organization did not properly document evidence of an effective control activities to provide reasonable assurance of federal compliance. Entities applying for sub-awards from the Organization are required to self-certify that they are not debarred, suspended, or otherwise excluded, however there is no documentation to support verifying this information using the System for Award Management (SAM.gov). Effect or Potential Effect: As a result, the Organization does not appear to meet the program compliance requirement. Questioned Costs: $0. Context: We were unable to obtain sufficient appropriate audit evidence to determine federal compliance, however our testing of direct expenditures during the audit noted no apparent covered transactions with debarred, suspended, or otherwise excluded entities, resulting in no questioned costs. Repeat Finding: Not applicable. Recommendation: Formal procedures should be established to ensure compliance with federal debarment and suspension requirements. Views of Responsible Official: See Corrective Action in Part D below.