Finding 1137285 (2023-004)

Criteria The Organization is required to perform and document suspension and debarment searches for potential vendors prior to procuring services. Condition Evidence was not in place to ensure that the Organization is abiding by the suspension and debarment searches for potential vendors in accordance with 2 CFR Part 200. Context During the year ended May 31, 2023, the Organization engaged a single contractor for this program. Upon testing this contractor, we found that the Organization lacked documentation to demonstrate that the suspension and debarment verification procedures, as outlined in the Organization’s procurement policy, were conducted prior to securing the services. Consequently, we could not conclude that this verification was performed in a timely manner. The Organization incurred expenditures totaling $74,013 with this contractor during the year ended May 31, 2023. The remaining program expenditures of $10,804,804 were payroll-related and not subject to suspension and debarment requirements. Cause The Organization was not aware of the necessity to maintain the documentation of its suspension and debarment search procedures. Effect Without abidance of the documentation requirements of 2 CFR Part 200, there is an increased risk that procurement activities may not be conducted in compliance with federal requirements, potentially leading to unallowable costs or questioned costs. Questioned Costs None. Repeat Finding No. Recommendation We recommend that management ensure all procurement policy requirements are performed and documented prior to entering into procurement transactions. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.