Finding Text
Federal Agency: U.S. Department of Agriculture Federal Program Name: Partnerships for Climate-Smart Commodities Assistance Listing Number: 10.937 Federal Award Identification Number and Year: NR233A750004G064 - 2023 Award Period: 7/20/2023-6/30/2028 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Procurement, Suspension and Debarment. Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have policies and procedures in place to following in relation to procurement, suspension, and debarment. Condition: During our testing, we noted that the Organization did not implement a formal procurement policy or suspension and debarment policy to follow but instead followed each federal agencies policies as part of the federal award. During our testing, we noted the Organization did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned costs: None Context: While performing audit procedures, it was noted that the Organization did not implement a formal procurement policy along with no separate policies for suspension and debarment. During our testing, it was noted that the Organization did not maintain documentation over verification the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration prior to entering into a signed contract. Cause: The Organization follows regulations implemented by each federal contract and works with the federal agency contact to ensure compliance with purchasing. The Organization did not implement entity-wide procedures and policies to be followed in accordance with the Uniform Guidance for procurement, suspension, and debarment. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that the Organization implement a procurement policy that addresses the five procurement methods allowed under Uniform Guidance. Internal controls should be implemented to make sure procurement methods are properly followed and documentation is maintained. We recommend the Organization develop and implement controls to ensure compliance with suspension and debarment requirements and keep an electronic or manual file indicating that such review was done to verify that they are following compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.