Finding Text
Finding No.: 2024-001
Federal Agency: U.S. Environmental Protection Agency
AL No. and Title: 66.600 – Environmental Protection Consolidated Grants for the Insular
Areas – Program Support
Federal Award No.: Various
Area: Procurement, Suspension and Debarment
Questioned Costs: $0
Criteria:
2 CFR section 180.300 requires entities that enter into a covered transaction must verify that the
person with whom you intend to do business is not excluded or disqualified by:
(a) Checking SAM.gov Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person.
Condition:
Of 5 out 5 samples tested (100%), GWA did not perform the required verification of persons
required by 2 CFR section 1800.300. No questioned cost was identified as subsequent checking of
the samples in SAM.gov did not result in identification of suspended or debarred individuals.
Cause:
There is no formalized procedure in place for verifying the debarment, suspension, or exclusion
status of entities prior to entering into covered transactions.
Effect or potential effect:
GWA is in noncompliance with the applicable requirements.
Recommendation:
GWA should develop and implement a formal procedure for verifying the debarment, suspension,
or exclusion status of entities prior to entering into covered transactions, which includes regular
checks against the System for Award Management (SAM) database and other relevant resources.
Views of Responsible Officials:
GWA acknowledges the audit finding and concurs that a verification through the System for
Award Management (SAM.gov) was not completed and documented prior to executing a contract
with the identified vendors. GWA recognizes the importance of complying with federal
requirements and preventing ineligible parties from participating in federally funded projects.