Finding 1148193 (2023-004)

-
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-07-22

AI Summary

  • Core Issue: Management failed to provide proof that suspension and debarment checks were done before starting procurement for federal grants.
  • Impacted Requirements: Compliance with 2 CFR 180.300, which prohibits contracting with suspended or debarred entities.
  • Recommended Follow-Up: Implement procedures to obtain vendor certifications or document checks against the SAM website, and ensure all contract documentation is properly maintained.

Finding Text

Finding 2023-004 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Federal Agency: U.S. Small Business Administration and U.S. Department of Treasury Federal Program: Congressional Grants, ALN No. 59.059, Award SBAHQ2210040, Award Period 9/1/2022 – 3/31/2023; and COVD-19 Coronavirus State and Local Fiscal Recovery Funds, ALN No. 21.027, Award FY22- BASE-BTBC, Award Period 6/16/2022 – 6/15/2024 Compliance Requirement: Suspension and Debarment Repeat Finding: No Condition: During our testing of three covered transactions (all vendors), we noted that management was not able to provide supporting documentation that suspension and debarment procedures were performed before the start of the procurement activity. Questioned Costs: None Context: The finding was noted for two of two vendors tested for 59.059 and the one vendor tested for 21.027. Criteria: 2 CFR 180.300 prohibits entities from contracting under covered transactions to parties that are suspended or debarred from doing business with the federal government. A contract for goods or services is a covered transaction if awarded as a grant or payment for specified use and if the amount of the contract is expected to equal or exceed $25,000. In order to comply with federal suspension and debarment requirements, the Organization can perform a search in the federal System of Award Management (SAM) website, which tracks the entities that the federal government has determined are ineligible to receive federal funding; collect a certification from the entity; or add a clause or condition to the contract. Cause: Federal grants were new to the Organization and the required suspension and debarment checks were not done timely. Effect: The finding indicates that there could be some process improvements in how contracts are reviewed, documented and maintained to provide evidence the compliance requirements are being met. Recommendation: We recommend that the Organization either obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on the SAM website. We recommend that Organization has proper procedures in place to ensure that all contractual documentation is maintained and able to be located.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 571748 2023-003
    Material Weakness
  • 571749 2023-004
    Significant Deficiency
  • 571750 2023-005
    Significant Deficiency Repeat
  • 571751 2023-004
    -
  • 571752 2023-005
    Significant Deficiency Repeat
  • 1148190 2023-003
    Material Weakness
  • 1148191 2023-004
    Significant Deficiency
  • 1148192 2023-005
    Significant Deficiency Repeat
  • 1148194 2023-005
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.77M
59.059 Congressional Grants $958,000
11.024 Build to Scale $495,754
11.307 Economic Adjustment Assistance $469,720