Finding Text
Information on the Federal Program
Federal Agency: United States Department of Education
Program Names: Special Education – Grants for Infants and Families
AL: 84.181
Federal Award Year: 2023
Federal Agency: United States Department of Education
Program Names: Special Education Cluster (IDEA)
AL: 84.027, 84.173
Federal Award Year: 2023
Federal Agency: United States Department of Education
Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief
(ARP ESSER)
AL: 84.425U
Federal Award Year: 2023
Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a
covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction.
Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and
employees meeting the covered transaction threshold.
Context: Based on our testing, we noted that while none of the sample of vendors and employees tested
grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant.
Questioned Costs: None noted
Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the
SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties.
Identification as a Repeat Finding, if applicable
N/A
Recommendation: We recommend the Organization implement a process to compare all vendors meeting the
$25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM.
Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.