Finding Text
2024-002—SUSPENSION AND DEBARMENT Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instance of Noncompliance related to Federal Awards Funding Agency U.S. Department of Agriculture (“USDA”) Programs Beginning Farmer and Rancher Development Program; Award: BFRDP-2023-49400-40894 (AL 10.311); Period: 09/15/2023-09/14/2026 Partnerships for Climate-Smart Commodities; Award: USDA/NR243A750004G005 (AL 10.937); Period: 11/02/2023 -11/01/2028 Questioned Costs None identified Statement of Condition Quivira does not have a process to or adequately document its review process to confirm vendor suspension and debarment status prior to entering into federally funded transactions. Also, the policies and procedures do not have clear procedure of vendor checking for debarment and suspension. Quivira has checked three entities during the Audit with no negative results. Criteria Non-Federal entities must ensure covered transactions are not with excluded parties (2 CFR Part 180, e.g., §180.300) as required by 2 CFR §200.214. Verification may be via SAM.gov, certification, or contract clause, with documentation retained. Cause Procurement policy lacks clear Suspension and Debarment steps and required documentation; staff is not trained on timing/evidence. Effect or Potential Effect Not adequately verifying suspension and debarment could result in Quivira engaging federally funded vendors who are prohibited from participating in federal programs, potentially causing disallowed costs, repayment obligations, or the loss of future federal funding. Recommendation We recommend Quivira: Update procurement policies promptly to fully comply with all applicable federal procurement guidelines. Clearly define the federal small purchase threshold and include procedures for obtaining price quotations. Establish and implement documented processes for verifying and recording suspension and debarment checks before engaging in covered transactions. Provide ongoing training for procurement staff to ensure proper understanding and consistent application of federal procurement standards, specifically regarding small purchase procedures and suspension/debarment checks. Views of Responsible Officials and Planned Corrective Action Management agrees with the recommendation. To address this significant deficiency, Quivira Coalition will: Action Step Detail Date Responsible Party Update its Procurement Policy to fully comply with all applicable federal procurement guidelines including clearly defining the federal small purchase threshold, updating procedures for obtaining price quotation, adding procedures for checking suspension & debarment and documenting results before engaging in transactions. 10/31/25 Drafting: Operations Director & Executive Director Review Changes: Board of Directors financial committee Approval: Board of Directors Implement the procedure to check suspension or debarment with potential subrecipients, contractors and other persons related to covered transactions before entering into a covered transaction by the methods given in 2 CFR § 180.300. The documentation showing the check or certification that a person is not suspended or debarred will be saved in the grants and financial files. Once it has been confirmed the person is not suspended or debarred, then the transaction may be entered into. 10/31/25 Operations Director & Executive Director Conduct an annual training for all staff currently involved with government awards including programmatic staff plus financial and grant management staff on the updated procurement policies with special focus on small purchase procedures and suspension/debarment checks. It will also build into its grant lifecycle regular review of these procedures during application/negotiation, implementation and reporting phases. 11/30/25 Operations Director and Grants manager Incorporate a semi-annual review of procurement files to ensure compliance with the new procedures. Findings from these reviews will be reported to management. 1/31/26 Operations Director