Finding Text
U.S. Department of Housing and Urban Development #14.251 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants 2024-006 Lack of Documentation for Suspension and Debarment Verification Criteria: Per 2 CFR §180.300 and 2 CFR §200.214, entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify a vendor's status using SAM.gov and maintain documentation as evidence of compliance with this requirement. Condition: While the Organization has a written procurement policy that references compliance with federal procurement standards, there was no documentation to demonstrate that suspension and debarment verifications were performed for vendors or contractors paid with federal funds during the year. Cause: Although the Organization has a procurement policy in place, the procedures for documenting suspension and debarment verification were not consistently followed or retained. Effect: Without documentation of suspension and debarment checks, there is an increased risk that federal funds could be expended with a vendor or contractor that is ineligible to receive federal awards, resulting in potential noncompliance with federal regulations. Questioned Costs: None noted. Recommendation: We recommend the Organization strengthen implementation of its procurement policy by requiring documentation of suspension and debarment checks be included in all procurement files for federal funded contracts. This may include saving screenshots or printouts of the SAM.gov search results, retaining vendor verification logs, or using automated tools if available. Documentation should be maintained in accordance with federal record retention requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees documentation must be retained. Corrective Action: Management has implemented a formal process to document vendor eligibility verficiation. As of FY 2025, all vendors are revewied in SAM. gov prior to payment or contract execution, and a screenshot or PDF of the verification is saved to the Vendor Verification Log. The Grants & Finance Manager maintains this documentation as part of the procurement file.