Finding 1155837 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-10-07

AI Summary

  • Core Issue: The agency failed to verify that a vendor was not suspended or debarred before procurement, violating compliance requirements.
  • Impacted Requirements: This finding relates to the need for compliance with 2 CFR section 180.995 regarding vendor eligibility.
  • Recommended Follow-Up: Amend the procurement policy to include checks for suspension/debarment compliance to mitigate future risks.

Finding Text

Federal Agency: Department of the Interior Federal Program Name: Boston Harbor Islands Partnership - World's End Carriage Road Restoration Assistance Listing Number: 15.947 Federal Award Identification Number and Year: N/A Pass-Through Agency: National Park Service Pass-Through Number(s): P24AC02282 - 2023 Award Period: 10/01/2023 - 09/30/2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matter Criteria or specific requirement: 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: Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 2 (of 2) selections tested. Entire population was tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: N/A. Recommendation: We recommend the procurement policy be amended to include language that would require compliance with Uniform Guidance suspension/debarment requirements. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Department of Interior Boston Harbor Islands Partnership – World’s End Carriage Road Restoration Assistance Listing No. 15.947 Recommendation: We recommend the procurement policy be amended to include language that would require compliance with Uniform Guidance suspension/debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Suspension/Debarment: We have enhanced our written policies and document retention procedures around suspension/debarment checks, including comprehensive grant kick-off staff training by the Grants and Restricted Funds Manager and a new pre-award check-list to ensure debarment checks are completed prior to procurement. We are also exploring a custom integration with NetSuite's SuiteScript and SAM.gov Exclusions API to continually monitor vendor eligibility. Name(s) of the contact person(s) responsible for corrective action: Brian Therrien, Chief Financial Officer, 617-456-5253

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1155836 2025-001
    Material Weakness Repeat
  • 1155838 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.947 Boston Harbor Islands Partnership $323,103
15.929 Save America's Treasures $252,791
45.149 Promotion of the Humanities Division of Preservation and Access $177,957
11.473 Office for Coastal Management $156,659
14.218 Community Development Block Grants/entitlement Grants $120,000
15.623 North American Wetlands Conservation Fund $28,625
45.025 Promotion of the Arts Partnership Agreements $27,280
10.912 Environmental Quality Incentives Program $15,527
45.301 Museums for America $13,822
66.456 National Estuary Program $3,849