Finding Text
2023-003 – Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program: Arts in Education Federal Assistance Listing Number: 84.351 Pass-through Entity: Not applicable. Award Identification Number: S351A210115 and U351D180067 Year: 2022 and 2023 Criteria: 2 CFR §180.300 and 2 CFR §200.213 require non-federal entities to verify that contractors and subrecipients are not suspended or debarred from participation in federal programs. This verification must be accomplished by checking the System for Award Management (SAM), collecting a certification from the contractor, or adding a clause or condition to the covered transaction. Condition: During our testing, we noted the Organization did not maintain documentation to support that internal controls were performed to ensure vendors were not suspended or debarred prior to entering into the contract. Context: During our testing of 2 out of 3 vendors whose transactions exceeded the covered transaction threshold, we noted that while the Organization did not contract with any suspended or debarred vendors, there was no documentation of internal controls or procedures in place to verify vendor suspension or debarment status prior to entering into the covered transactions. Cause: The Organization was unable to locate documentation to support the performance of procedures to ensure vendors were not suspended or debarred. Effect: Without documented internal controls, there is an increased risk that the Organization could inadvertently enter into covered transactions with suspended or debarred vendors, resulting in noncompliance with federal requirements. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the Organization establish and document internal controls and procedures to verify and retain evidence that vendors are not suspended or debarred prior to entering into covered transactions, in accordance with federal requirements. Views of Responsible Officials: See Corrective Action Plan.