Finding Text
2024-001 – Suspension and Debarment
Material Weakness
Federal Program: Research and Development Cluster
Assistance Listing Number(s):
16.817 – Byrne Criminal Justice Innovation Program
16.525 – Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault and Stalking on
Campus
47.084 – NSFT Technology, Innovation, and Partnerships
47.074 – Biological Sciences
47.076 – Education and Human resources
47.070 – Computer and Information Science and Engineering
11.417 – Sea Grant Support
Criteria: The Federal Government requires that 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, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The University was not able to provide an audit trail to support the verification that a vendor was not suspended and debarred before entering into a contract.
Cause: The University does not have a control and/or process in place to ensure that the audit trail surrounding suspension and debarment verification is maintained.
Effect or Potential Effect: There is a possibility of the University entering into a contract with a vendor or subrecipient that is suspended or debarred.
Questioned Costs: None.
Context: Due to the University not having an audit trail for their internal controls around suspension and debarment verification, RSM evaluated the suspension and debarment compliance requirement as having a high level of control risk.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and implement additional control to ensure an audit trail is maintained surrounding the verification that vendors are not suspended and debarred.
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.