Finding Text
Federal Agency: United States Department of Education
Federal Program Name: Teacher Quality Partnership Program
Assistance Listing Number: 84.336
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or Specific Requirement: Under the Uniform Guidance, nonfederal entities are prohibited
from contracting with or making subawards under covered transactions to parties that are suspended or
debarred. “Covered transactions” include contracts for goods and services awarded under a
nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or
exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All nonprocurement
transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of
award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR
section 180.215.
Condition: We tested five subrecipients paid over $25,000. One of the five tested did not have any
documentation to support that the University verified the subrecipient was not suspended or debarred
at the time of executing the subaward agreement. The University stated they completed this review
however there was no documentation to support the completion of this step prior to entering into a
covered transaction. Per review of the suspension and debarment list at the time of testing, we noted
the subrecipient was neither suspended nor debarred.
Questioned Costs: None
Context: During testing, it was noted there was no documentation retained to ensure the SAM
verification was done prior to executing the subaward agreement. In addition, there was no
documentation of a second review to ensure the subrecipient was not suspended or debarred.
Cause: The control system to prevent payment to a suspended and debarred vendor was not in place.
Effect: The University could have entered into a covered transaction with a subrecipient who is
suspended or debarred.
Repeat Finding: No.
Recommendation: We recommend the University review its existing policies to ensure it is up to date
with federal regulations. We also recommend documenting the subrecipient was checked on the
SAM.gov website prior to executing the subaward agreement. A secondary review should be performed
prior to payment. This second review should be documented and retained to support the suspension
and debarment requirements were followed and completed before entering into a covered transaction.
Views of Responsible Officials: There is no disagreement with the audit finding.