Finding Text
Condition:
The Organization did not have documentation related to the suspension and debarment testing performed on vendors.
Criteria:
According to 2 CFR Section 200.318 and 2 CFR Section 200.326 of the Uniform Guidance, non-federal entities other than states must follow procurement standards when operating federal programs and the procurement procedures required depend on the amount of the transaction.
Cause:
The Organization was in the process of implementing the draft procurement policy as of June 30, 2024. The policy is properly designed and follows the Uniform Guidance. However, the policy was not implemented during the period under audit.
Effect:
There was an increased risk that the Organization was contracting and awarding contracts to suspended or debarred vendors..
Repeat Finding:
No
Questioned Costs:
None reported
Recommendation:
We recommend that the Organization implement a process to perform suspension and debarment testing as required by their procurement policy, and that as part of this process they maintain adequate supporting documentation and records to document suspension and debarment and the procedures performed to comply with the applicable CFR sections. This could include the use of standard forms and templates for suspension and debarment testing.
Views of Responsible Officials and Planned Corrective Action:
We concur with the auditor’s finding and will develop an updated procurement policy that includes maintaining adequate supporting documentation and records regarding suspension and debarment procedures performed.