2024-002 – Documentation of Controls over Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment, Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, All Awards. Auditor Description of Condition and Effect. During our testing of suspension and debarment for three vendors and six subrecipients, it was determined that the Organization did not verify that vendors or subrecipients were not suspended, debarred or otherwise excluded when the Organization contracted with them to provide goods or services for five of the nine vendors and subrecipients. The searches at www.sam.gov were done in early 2025 by management, which was well after the date of the applicable contractual agreement and expenditure activity. The failure to monitor suspension and debarment could cause funds to be disbursed to vendors or subrecipients who are not eligible to have goods and services purchased with federal monies. Auditor Recommendation. We recommend that the Organization retain documentation of their procurement process including checking vendors for potential exclusions from federal award work. We further recommend that these checks be done prior to entering into a contractual agreement. Corrective Action. LEAP will be following the recommendation of retaining all documentation of our procurement process including the checking of vendors both at state and federal levels for any potential exclusions from federal award work, and ensuring these checks be done prior to contract execution. LEAP will be substantially modifying its procurement policy that is part of its Grants Management SOP in order to more explicitly detail expectations and procedural steps to meet the requirements of Uniform Guidance with regards to sequence of events leading up to contract execution, including the state and federal checks for exclusion. Further, LEAP’s leadership will be holding a module within the aforementioned internal training for all management team members to walk through a new check list tool that aligns with policy and Uniform Guidance, and case study exercise will also hit on this topic to ensure learning occurs around the internal controls improvements made with policy revamp. Responsible Person. Tony Klisch, LEAP CFO Anticipated Completion Date. August 31, 2025