Finding Text
2023-004 Inactive SAM Registration Impacting Eligibility Compliance Requirement Special Tests and Provisions Requirement Category Significant Deficiency in Internal Controls and Noncompliance Federal Agency U.S. Department of the Treasury Pass-Through Entity Puerto Rico Fiscal Agency and Financial Advisory Authority ALN 21.027 Federal Program COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Small Business Administration ALN 59.075 Federal Program COVID-19 - Shuttered Venue Operators Program Federal Agency U.S. Department of Homeland Security through the Federal Emergency Management Agency Pass-through Entity Central Office for Recovery, Reconstruction and Resiliency ALN 97.036 Federal Program Disaster Grants - Public Assistance (Presidentially Declared Disasters) Criteria § 25.200 Requirements for notice of funding opportunities, regulations, and application instructions. (a) …… (b) …… (1) Be registered in SAM.gov before submitting an application; (2) Maintain a current and active registration in SAM.gov at all times during which it has an active Federal award as a recipient or an application under consideration by a Federal agency. The applicant or recipient must review and update its information in SAM.gov annually from the date of initial registration or subsequent updates to ensure it is current, accurate, and complete. If applicable, this includes identifying the applicant's or recipient's immediate and highest-level owner and subsidiaries, as well as providing information on all predecessors that have received a Federal award or contract within the last three years; and Condition The Corporation’s SAM registration expired on September 6, 2023. Cause The Corporation has been unable to update the SAM’s registration due to problems with the platform to correct their physical address. Effect By not updating the SAM registration, the Corporation may become ineligible to receive federal funds, considering it is a prerequisite for receiving federal grants. In addition, the Corporation could confront that any ongoing contracts or grants may be delayed or suspended until the registration is updated, might face additional administrative burdens to rectify the lapse, which can include reapplying for registration and addressing any compliance issues, and there could be a negative impact on the Corporation's reputation with federal agencies, potentially affecting future funding opportunities. Questioned Costs None Recommendation We recommend the immediate update of the SAM registration, considering that maintaining an active and up-to-date SAM registration is crucial for ensuring continued eligibility and smooth operations with federal funding. Views of responsible officials Refer to Unaudited Corrective Action Plan (Unaudited)