Finding 1130434 (2022-005)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2025-04-03

AI Summary

  • Core Issue: CFSC failed to verify subrecipient suspension or debarment status before finalizing subawards.
  • Impacted Requirements: This violates 2 CFR 200.403(a), which mandates verification before entering into transactions.
  • Recommended Follow-Up: Management should enhance policies to ensure timely verification of suspension and debarment status during the pre-award process.

Finding Text

Federal Agency: U.S. Department of Agriculture Forest Service Federal Program Name: Cooperative Forestry Assistance - Pass-Through Agency: N/A Assistance Listing Number: 10.664 Federal Award Identification Year: 2021 Award Period: 09/01/21-08/31/26 Type of Finding: Other Matters - Significant Deficiency in Internal Control Criteria: 2 CFR 200.403(a) - 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. Condition: For two subrecipient samples that were selected, verification of subrecipient's suspension or debarment status was not verified until after the subaward agreement was effective. Context: A nonstatistical sample of 6 out of 20 subrecipients were selected for testing for the Cooperative Forestry Assistance program. The condition noted above was identified during our procedures over CFSC’s subrecipients. Effect: CFSC did not verify suspension or debarment status timely which could result in naming a subrecipient as an award recipient who is potentially suspended or debarred. Cause: CFSC did not consistently ensure that Suspension or Debarment status was verified timely before naming the subrecipients tested as award recipients. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management strengthen its current policies and procedures to ensure that Suspension and Debarment Status is verified for each subrecipient applicant during its pre-award subrecipient screening process. Management’s Views: See separate corrective action plan.

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles Period of Performance Significant Deficiency

Other Findings in this Audit

  • 553991 2022-004
    Significant Deficiency Repeat
  • 553992 2022-005
    Significant Deficiency
  • 553993 2022-006
    Significant Deficiency Repeat
  • 553994 2022-007
    Significant Deficiency Repeat
  • 553995 2022-008
    Material Weakness
  • 553996 2022-009
    Material Weakness Repeat
  • 553997 2022-010
    Material Weakness Repeat
  • 1130433 2022-004
    Significant Deficiency Repeat
  • 1130435 2022-006
    Significant Deficiency Repeat
  • 1130436 2022-007
    Significant Deficiency Repeat
  • 1130437 2022-008
    Material Weakness
  • 1130438 2022-009
    Material Weakness Repeat
  • 1130439 2022-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.473 Office for Coastal Management $685,222
10.698 State & Private Forestry Cooperative Fire Assistance $1,249
10.664 Cooperative Forestry Assistance $-86,652