Finding Text
Criteria or Specific Requirement
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions.
Condition and Context
During our testing over suspension and debarment, we noted one instance in which the Organization was unable to locate documentation that a suspension and debarment check was performed prior to entering into a transaction with a vendor.
Effect
Noncompliance results in possible federal funds provided to ineligible vendors.
Questioned Costs
None identified.
Cause
The Organization does not have internal controls in place to ensure compliance with federal regulations or the terms and conditions of the federal award.
Recommendation
We recommend the Organization implement a process to ensure that procurement and suspension and debarment documentation is retained.
Views of Responsible Officials
The Organization has a program called Compliatric that the Organization can load all of its vendors into and it will check on a monthly basis the registries for Debarment and Exclusions from Federal Programs with a log to track this screening. The Organization has changed the accounts payable process to include adding all new vendors to the Compliatric list for screening compliance. The Organization feels this will ensure ongoing compliance of all vendors on a monthly basis going forward. Any matches will require either the Risk and Compliance Manager or the CFO to review and validate the match or identify that the match is an error. If validation is found to be correct all purchasing and use of that vendor will be terminated going forward.