Finding Text
Information on the Federal Programs: All Programs
Criteria: CFR 200.213 states that 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; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Additionally, as outlined in each Department of State award, recipients of U.S. Government funds must adhere to the United States Government’s requirements on screening all potential vendors, suppliers, subcontractors/grantees and employees against the United States Department of State’s Terrorism watch list. The screening of all potential vendors, suppliers, sub-contractors/grantees and employees must be documented in writing.
Condition: The Organization did not provide timely/contemporaneous documentation to support its screenings for its potential and current vendors, suppliers, contractors, employees, etc. that were paid with Federal funds during the year under audit.
Cause: The Organization did not follow its internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment.
Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Organization's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systemic in nature.
Effect: The Organization could make payments to an entity or individual that has been debarred or suspended by the US Government; such costs would be disallowed, and the Organization could face consequences for lack of compliance.
Questioned Costs: None noted.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the Organization adhere to its policy of how screenings will be performed and how contemporaneous documentation will be maintained in order to demonstrate compliance with government regulations.