Finding Text
2023-08
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: Community Compass Technical Assistance and Capacity Building
Assistance Listing Number: 14.259
Federal Award Identification Number and Year: N-15-IT-TA-0001, Year 2016
Award Period: 03/17/16-09/12/23
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Criteria:
When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
This verification may be accomplished by
(1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition:
For one of the six procured vendors selected for testing, NAIHC did not verify suspension and debarment status of one vendor prior to contracting the vendor.
Context:
A nonstatistical sample of six out of twenty procured vendors were selected for testing for the Community Compass Technical Assistance and Capacity Building program. The condition noted above was identified during our procedures over the Procurement compliance requirements.
Effect:
NAIHC contracted with a vendor without verifying suspension and debarment status.
Cause:
NAIHC did not verify suspension and debarment status.
Recommendation:
We recommend that NAIHC strengthen its current policies and procedures to ensure that evidence of verifying suspension and debarment status is retained.
Management’s View:
See Separate Corrective Action Plan.