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Finding: 2024-003 Procurement and Suspension and Debarment Finding Type: Noncompliance, Significant Deficiency Identification of the Federal Program(s): U.S. Department of Health and Human Services: Federal Assistance Listing #93.185 – COVID-19 – Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects Criteria: The code of federal regulations – 2 CFR section 180.300 states that: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified from receiving federal funds. You do this by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: During our review of two contractors (from a population of six contractors), we noted the following: For one contractor, NUL did not provide any evidence to support that a SAM.gov suspension and debarment verification had been performed or that a suspension and debarment clause was included in the contract. It should be noted that NUL, in 2025, amended the contract to include the suspension and debarment clause. Cause: NUL indicated that this issue occurred due to a clerical error, whereby the suspension and debarment clause was initially included in the draft contract but was accidentally omitted while other updates were being incorporated into the contract. Effect: NUL was not in compliance with the requirements noted above. Questioned Costs: None. Repeat Finding: Not a repeat finding. Recommendation: We recommend that NUL ensure that personnel responsible for compliance and contracting are familiar with all suspension and debarment requirements. We recommend that NUL develop control procedures to ensure that contractor compliance reviews are timely performed and documented, with evidence of such maintained. Evidence of such reviews may include, but not be limited to, the existence of the appropriate clause in contracts, copies of suspension and debarment certifications from contractors, and/or documentation of verification via the SAM.gov website. View of Responsible Officials: See management’s corrective action plan.