Finding Text
Finding 2023-007: Suspension and Debarment
Information on the Federal Program: 97.024 - Emergency Food and Shelter National Board
Program
Type of Finding: Material Weakness in Internal Control over Compliance and Material NoncomplianceCriteria: Under 2 CFR §200.213, non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a
certification from that person; or (c) Adding a clause or condition to the covered transaction with that
person.
Condition: During our testing over Suspension and Debarment, we determined that SAMU either did
not perform screenings, or did not document the screening date on potential or current vendors,
suppliers, contractors or employees that were paid with Federal funds.
Cause: SAMU does not have a formal internal policy with respect to screening vendors, suppliers,
contractors and employees in order to adhere to compliance over suspension and debarment.
Effect or Potential Effect: Failure to screen, in a timely manner (before contract date or payment
occurs) potential and current vendors, suppliers, contractors and employees increases the potential
that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the
United States Government.
Questioned Costs: $24,000
Context: Out of 4 samples selected for testing, we noted the following: 2 samples did not have
evidence of the date of the SAM check being performed; 1 sample had a SAM check date performed
after execution of the contract with the vendor; 1 sample did not have a SAM check performed at all.
The sample is representative of the population.
Identification as a Repeat Finding, if Applicable: 2022-007
Recommendation: We recommend that management develop and implement a formal policy on
suspension and debarment. All screenings should be conducted prior to entering into an agreement
with a vendor. Additionally, evidence of documentation should include the date of when the SAM check
was performed. We recommend that SAMU notify all employees of this policy and ensure that it is
enforced during the upcoming year.