Finding Text
Federal Agency: Department of Education Federal Program: EIR Program – Early-Phase Grants Assistance Listing Number: 84.411C Federal Award Identification Number and Year: S411C210073 - 2021 Award Period: 12/15/2021 – 12/15/2026 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matter Criteria or specific requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 5 (of 5) selections tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: N/A. Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Views of responsible officials: There is no disagreement with the audit finding.