Finding Text
Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award.
Condition: Under 2 CFR part 180, the Organization is required to verify suspension or debarment from the excluded parties list system regarding compliance. Though the Organization did not have a policy for suspension and debarment, the Organization complied with the requirements.
Effect: Not having a suspension and debarment policy may result in funds to be returned back to grantor and/or impact future funding.
Cause: Supporting suspension and debarment documentation for the acquisition of property and services were not properly established in part due to several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight.
Questioned Costs: None
Recommendation: We recommend the Organization strengthen its policies and procedures to ensure suspension and debarment is adequately documented that goods and services purchased in accordance with Uniform Guidance and other federal guidelines. In addition, the Organization should verify that all vendors under covered transactions are not listed on the excluded parties list system by performing a search on sam.gov and maintaining the results of such search in the vendor’s file.