Finding Text
Criteria or Specific Requirement – Per 2 CFR §180.300 and §200.214, non-federal
entities are prohibited from entering into covered transactions (e.g., contracts or
subawards expected to equal or exceed $25,000) with parties that are suspended,
debarred, or otherwise excluded from participation in federal programs.
Conditions – Verification of SAMS.gov vendors was not performed. Context – During our testing of procurement, we sampled nine expenditures
totaling $367,163. The total population of procurement expenditures charged to
the program was $800,000. We noted that all nine selections of expenditures did
not have SAMS.gov verification documentation.
Cause – The Association did not have a formal process or checklist to ensure that
vendors were checked against the SAM.gov exclusion list before contract award.
Procurement staff were not trained on this requirement.
Effect – Use of non-approved vendors could have occurred. However, as part our
audit procedures, we determined that the expenditures were made with
contractors which were not suspended or disbarred and were approved on the
SAMS.gov website.
Recommendation – We recommend the Association implement a formal policy and
procedure to verify all vendors against SAM.gov for covered transactions exceeding
$25,000. Staff responsible for federal procurement should be trained, and
documentation of vendor status verification should be retained with procurement
records.
Views of Responsible Officials and Planned Corrective Actions – Procurement Policy
was updated and documentation will be maintained to support vendor verification
in the future.