Finding Text
Finding 2024-004: Suspension and Debarment (Significant Deficiency)
Information on the Federal Program: 45.301 - Institute of Museum and Library Services
Criteria: Under 2 CFR §200.213, non-Federal entities are subject to the non-procurement debarment
and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These
regulations restrict awards, subawards, and contracts with certain parties that are debarred,
suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities. The non-Federal entity must verify that the person with whom you intend to do business is
not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that
person; or (c) Adding a clause or condition to the covered transaction with that person.
Condition: During our testing over Suspension and Debarment, we determined that the Museum did
not perform screenings on the vendors selected for testing.Cause: The Museum does not have a formal internal policy with respect to screening vendors,
suppliers, contractors and employees in order to adhere to compliance over suspension and
debarment.
Effect or Potential Effect: Failure to screen, in a timely manner (before contract date or payment
occurs) potential and current vendors, suppliers, contractors and employees increases the potential
that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the
United States Government.
Questioned Costs: None noted.
Context: We noted that vendors, suppliers, contractors and employees selected for testing did not
have a formally documented Suspension and Debarment check conducted prior to engagement.
Identification as a Repeat Finding, if Applicable: Not a repeat finding.
Recommendation: We recommend that management develop and implement a formal policy on
suspension and debarment. This policy should include a threshold for when vendors, suppliers,
contractors and employees should be screened. All screenings should be conducted prior to signing a
contract or issuing payment. We recommend that the Museum notify all employees of this policy and
ensure that it is enforced during the upcoming fiscal year.