Finding 1157970 (2024-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-30

AI Summary

  • Core Issue: The Organization failed to verify if vendors were suspended or debarred before procurement transactions over $25,000.
  • Impacted Requirements: Noncompliance with 2 CFR Section 200.214 and 2 CFR part 180 regarding vendor eligibility.
  • Recommended Follow-up: Implement a procedure to document vendor checks for suspension and debarment to ensure compliance.

Finding Text

2024-005 - Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment) Programs. Environmental and Scientific Partnerships and Programs; U.S. Department of State; ALN Number 19.017; Award Number SAQMIP23CA0021 Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During Procurement, Suspension and Debarment testing, the Organization could not provide evidence that they determined whether vendors are suspended or debarred. Cause. The Organization did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. None Recommendation. We recommend that the Organization adhere to the policy over suspension and debarment review to ensure they are contracting with vendors that are allowable. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

2024-005 - Procurement, Suspension and Debarment Auditor Description of Condition and Effect: During Procurement, Suspension and Debarment testing, the Organization could not provide evidence that they determined whether vendors are suspended or debarred. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Auditor Recommendation: We recommend that the Organization adhere to the policy over suspension and debarment review to ensure they are contracting with vendors that are allowable. Corrective Action: While the Organization has controls in place to ensure vendors are not suspended or debarred, management will ensure to have this process documented going forward. Responsible Person: Dora Gonzales Anticipated Completion Date: December 2025

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1157967 2024-002
    Material Weakness Repeat
  • 1157968 2024-003
    Material Weakness Repeat
  • 1157969 2024-004
    Material Weakness Repeat
  • 1157971 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.017 Environmental and Scientific Partnerships and Programs $1.57M
66.957 Greenhouse Gas Reduction Fund: National Clean Investment Fund $576,149