Finding 1095183 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-01-10
Audit: 337188
Organization: Ocean Conservancy, Inc. (DC)

AI Summary

  • Core Issue: The Organization lacks documentation proving that it checked vendors against the suspended or debarred list before contracting.
  • Impacted Requirements: This finding relates to compliance with 2 CFR Part 200, which mandates internal controls for procurement and vendor eligibility.
  • Recommended Follow-Up: Improve internal controls to ensure vendor reviews are conducted and documented properly to prevent potential noncompliance.

Finding Text

Suspension and Debarment Federal Agency: Department of Commerce Federal Program Name: Marine Debris Program Assistance Listing Number: 11.999 Federal Award Identification Number and Year: NA20NOS9990024 (October 1, 2023 – September 30, 2024), NA21NOS9990119 (September 1, 2021 – August 31, 2024) Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization. should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have documentation to support that internal controls were performed to ensure vendors were not suspended or debarred prior to entering into the contract. Questioned costs: None. Context: During our testing, it was noted that the Organization did not maintain documentation that it had reviewed vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. This exception was noted for 3 of 5 items tested, however, we were able to verify that the selected vendors were not suspended or debarred. Cause: The Organization was unable to locate documentation to support the performance of procedures to ensure vendors were not suspended or debarred. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Organization enhance controls to ensure an adequate process is in place to review potential vendors to determine they are not suspended or debarred and to ensure documentation to support this is maintained. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 518740 2024-002
    Significant Deficiency
  • 518741 2024-002
    Significant Deficiency
  • 1095182 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.999 Marine Debris Program $78,972