Finding Text
Federal agency: U.S. Department of Agriculture, Forest Service
Federal program: Partnership Agreements
Assistance Listing No.: 10.699
Federal Award No.: 21-PA-11132425-105, 23-PA-11132425-286, 23-PA-11132210-459,
23-PA- 11160100-496, 23-CS-11100400-018, 24-CS-11100100-044,
24-CS-11132420-094
Federal Award year: Multiple
Finding Type: Significant deficiency and non-compliance
Finding 2024-001: Significant Deficiency and Noncompliance Over Suspension and Debarment Check
Procedures
Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. Covered transactions include contracts for
goods and services awarded under a non-procurement transaction (e.g., grant or cooperative
agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2
CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e.,
subawards to subrecipients), irrespective of award amount, are considered covered transactions,
unless they are exempt as provided in 2 CFR section 180.215. 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 SAM.gov, (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: UHY noted that the Society did not perform suspension and debarment check before
entering into covered transactions with vendors.
Context and Effect: Without performing the required verification, there is a risk that the Society may
enter into covered transactions with vendors that are suspended or debarred.
Cause: There is no formalized step included in the procurement procedures to check for vendor
exclusions for suspension and debarment when utilizing federal grant funds.
Identification as a Repeat Finding, if Applicable: No.
Questioned Costs: None identified.
Recommendation: The Society should implement policies and procedures to ensure that the proper
verification of suspension and debarment is performed during the vendor selection process when
utilizing federal grant funds, ensuring that no federal grant funds go to excluded vendors.
Responsible Official: CFO of the Society
Views of Responsible Official and Planned Corrective Action: Management concurs with the audit
finding. See the accompanying managements corrective action plan for planned corrective action.