Finding Text
Criteria: According to 2 CFR Section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended, debarred, or otherwise excluded. Condition: The District had transactions in excess of $25,000 with one vendor that they did not check for suspension and debarment or have signed certifications. Questioned Costs: N/A. Context: Total payments to the vendor was $47,500. Effect: The District was at risk of making material payments to vendors who aren't allowed to do business with the federal government. There was no noncompliance, but there was no internal control in place to prevent noncompliance. Cause: Lack of oversight by the District. Recommendation: We recommend that the District check the Excluded Parties List System or collect certifications from any vendor that the District expects to spend more than $25,000 for the year. Management's Response: We were not aware of this requirement. We will begin making all significant vendors sign a certification.