Finding Text
Finding 2022-003: Suspension and Debarment Criteria or Specific Requirement: Title 2, subtitle A, chapter II, Part 200, subpart c, Section 200.214 – Suspension and debarment. Recipients of Federal funding must adhere to specific requirements on screening of all potential and current vendors, suppliers, contractors, subrecipients, employees, fellows, etc. to ensure the recipient is not conducting business with excluded parties (as defined by the United States Government). This screening process must also be documented in writing. Condition: UHU did not consistently perform the screening process for its potential and current vendors, suppliers, contractors, subrecipients, employees, etc. that were paid with Federal funds. Context: Payments were made during the fiscal year without performing the proper screening process. Our audit work in this area consisted of internal control testwork over a random sample of expenditures, as well as substantive testwork over transactions above a defined threshold from select expense accounts that were charged to the Federal program. The issue is deemed to be systemic. Cause: UHU did not have a formal policy in place with regard to suspension and debarment screenings, although they did occasionally perform screening of potential and current vendors, suppliers, contractors, subrecipients, and employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors, subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: Undetermined. Identification of Repeat Finding: 2021-003Recommendation: We recommend UHU establish policies and ensure that all types of parties (as noted above) are included, and educate its employees on the procedures necessary to ensure full compliance with this requirement. We also recommend that UHU document each of these screenings and retain them in the respective files, which should be completed prior to engaging in relationships with these parties. For ongoing relationships, UHU should consider performing screenings on an annual basis (and documenting them) to ensure continuous compliance in the event the suspension and debarment status of any of these parties changes. Lastly, we recommend UHU perform retrospective screenings on these parties to which it made payments during the fiscal year.