Finding 1143544 (2024-001)

2024 – 001 Suspension and Debarment Federal Agency: National Science Foundation (NSF) and Department of Energy (DOE) Federal Program Name: Mathematical and Physical Sciences (Construction of the Vera C. Rubin Observatory under the MREFC and Management, Operations and Maintenance of Vera C. Rubin) and LSST Commissioning Services for SLAC (DOE) Assistance Listing Number: 47.049 and 81.RD Federal Award Identification Number and Year: CSA AST-1202910 (July 2014 – December 2024), CSA AST-2211468 (October 2022 – September 2027), and DE-AC02-76SF00515 (April 2019 – September 2025) Pass-Through Agency: SLAC National Accelerator Laboratory Pass-Through Number(s): 194609 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award (UG) requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have documentation to support that internal controls were performed to ensure vendors were not suspended or debarred prior to entering into the contract. Questioned costs: None. Context: During our testing, it was noted that the Organization did not maintain documentation that it had reviewed vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. This exception was noted for 3 of 40 items tested, however, we were able to verify that the selected vendors were not suspended or debarred. Cause: The Organization was unable to locate documentation to support the performance of procedures to ensure vendors were not suspended or debarred. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No. Recommendation: We recommend AURA enhance controls to ensure an adequate process is in place to review potential vendors to determine they are not suspended or debarred and to ensure documentation to support this is maintained. Views of responsible officials: There is no disagreement with the audit finding.