Finding Text
2024-003 U.S. Department of Education, Assistance Listing #84.027/84.173 Special Education Cluster (IDEA) for the period July 1, 2023 through June 30, 2024
Criteria: In accordance with 2 CFR part 180, non-Federal entities are prohibited from contracting with parties that are suspended or debarred when a covered transaction is expected to equal or exceed $25,000 or meet certain other criteria specified in 2 CFR 180.220. The non-Federal entity must verify the contractor is not suspended or debarred by (1) checking the System for Award Management (SAM) exclusions maintained by the General Services Administration at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the contract with that entity.
Condition: During our disbursement test, we selected a consulting contract that did not include documentation that one of the three suspension and debarment verifications were performed.
Cause: Although the School’s procurement policy references the suspension and debarment requirements, the School does not have a procedure in place to ensure compliance with the requirement prior to contracting with a vendor.
Effect: The vendor could have been suspended or debarred from entering into a contract funded by Federal grants. Noncompliance can result in the grantor withholding Federal funds for the program.
Known Questioned Costs: None
Likely Questioned Costs: None
Recommendation: We recommend management review the requirements under 2 CFR part 180 and develop procedures to add to their Federal Procurement Manual to ensure that one of the three verifications is present prior to entering into a covered transaction.