Finding Text
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering &
Office of Cyber Infrastructure
AL No.: 47.050, 47.070, 47.079 & 47.080
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC-
1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818
(10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329
(10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061
(10/01/17 – 09/30/2022)
Pass Through Entity: Utah State University
MW2022-006 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
The auditor noted that CUAHSI failed to maintain and provide the proper records and support to
document their review of vendor files for covered transactions. Such failure led to noncompliance
with the procurement, suspension and debarment policies in accordance with the UG
for the year ended December 31, 2022. CUAHSI did not complete the verification of its 2022
vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to
be federally debarred, suspended or excluded.Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds and / or possible
suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2021-007.
Recommendation
CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement
process in compliance with 2 CFR section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.