Finding 1161833 (2024-002)

Finding No: 2024.002 Type: Significant Deficiency - Internal Control: Procurement Condition: We were not able to substantiate evidence of confirming suspension and debarment for vendors. Criteria: Under 2 CFR 200.214, non-federal entities must verify that subrecipients and contractors are not suspended, debarred, or otherwise excluded from participation in federal programs before entering into covered transactions. Checks should be performed using the System for Award Management (SAM). Internal control over compliance requirement related to suspension and debarment was not evidenced. Amount: not applicable Cause: The nonprofit does not have documented procedures to verify the suspension and debarment status of entities prior to awarding contracts or subawards. No evidence was available to confirm that such checks were performed for current awards. Effect or Potential Effect: Absence of adequate suspension and debarment screening increases the risk of federal funds being awarded to ineligible parties, potentially resulting in repayment of those funds, audit findings, and possible exclusion from future grant programs. Repeat Audit Finding: no Recommendations: Implement and document procedures requiring SAM exclusion checks prior to issuing federal subawards or contracts and maintain records of these checks. Provide staff training on regulatory requirements regarding suspension and debarment, and regularly review compliance to ensure ongoing adherence.