Finding Text
Finding 2024-002: 10.761 - U.S. Department of Agriculture - Water and Waste Technical Assistance and
Training - Material Weakness
Compliance
Requirement: Procurement and Suspension and Debarment
Criteria: Per Title 2 U.S. Code of Federal Regulations (CPR) Part 200, Subpart D, section
200.318(i), the non-Federal entity must maintain records sufficient to detail the history
of procurement and suspension and debarment.
Condition: During our testing of internal controls over compliance related to procurement and
suspension and debarment, we identified vendors/ contractors that were awarded without
required procurement and suspension and debarment documentation. Although there was
no documentation to support this verification being performed prior to the payment, we
noted that the vendors/contractors were not suspended or debarred.
Questioned Costs: None.
Cause: EWB-USA did not have adequate controls in place to ensure compliance with applicable
federal requirements.
Effect: EWB-USA was not in compliance with the procurement and suspension and debarment
provisions as prescribed in the CFR.
Recommendation: We recommend that EWB-USA implement procedures and controls to ensure that the
approval of contractors or vendors are adequately supported by sufficient documentation
and detail. In addition, this documentation should be retained, at a minimum, through the
completion of the contract.
Response: 1. Develop procurement procedures for procurement transactions under Federal
awards or subawards, including verification that a potential subrecipient is not
suspended, debarred, or otherwise excluded from receiving Federal funds. 2. Provide training to relevant staff on the new procedures for procurement
transactions including the verification of suspension and debarment for any
subrecipient awards and the importance of compliance with federal regulations.