Finding Text
Criteria: Per 2 CFR 200.214, when an entity enters into a covered transaction using federal awards with a vendor, the entity must verify that the vendor is not debarred, suspended, or otherwise excluded from receiving or participating in Federal award. The entity can do this by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that entity; or
(c) Adding a clause or condition to the covered transaction
Condition: C/CAG was unable to provide proof that it performed a suspension and debarment check on one of two vendors tested. C/CAG did not have evidence of a SAM.gov check on the vendor, or a timely certification from that vendor, or a clause or condition in the contract with that vendor asserting they were not suspended or debarred.
Cause: The vendor had been selected for an earlier similar non-Federally-funded project, and the new amended contract did not include the suspension/debarment clause as required by C/CAG’s policy.
Effect: One vendor of two tested vendors did not have sufficient evidence that they were not debarred or suspended from participating in Federal award activities.