Finding Text
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/02/24
Compliance Requirement Affected: Subrecipient Suspension & Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified
Opinion)
Criteria: 2 CFR 200.403(a) - 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.
Condition: For two subrecipient samples that were selected, verification of subrecipient's suspension or debarment status was not verified.
Context: A nonstatistical sample of 2 of 4 subrecipients were selected for testing for the Office for Coastal
Management program. Condition noted above was identified during our procedures over subrecipients.
Effect: CFSC did not verify suspension or debarment status, which could result in naming a subrecipient as an
award recipient, which is potentially suspended or debarred.
Cause: CFSC did not consistently ensure that Suspension or Debarment status was verified before naming the
subrecipients tested as award recipients.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that CFSC strengthen its current policies and procedures to ensure that Suspension and Debarment Status is verified for each subrecipient applicant during its pre-award subrecipient screening process.
Management’s Views: See separate corrective action plan.