Finding Text
Finding 2024-008: Suspension and Debarment Program Title: Defense Nuclear Nonproliferation Research Assistance Listing Number: 81.113 Federal Agency: U.S. Department of Energy Direct Award Identifying Numbers: DE-NA003862, DE-NA004179, DE-NA0004177 Federal Award Year: Year ended September 30, 2024 Program Title: Export Control and Related Border Security Assistance Listing Number: 19.901 Federal Agency: U.S. Department of State Direct Award Identifying Number: SAQMIP23CA0153 Pass-Through Entity Name, Pass-Through Identifying Number: The Research Foundation for SUNY, University at Albany, 3-98939 Federal Award Year: Year ended September 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: Under 2 CFR §200.213, non-Federal entities are prohibited from contracting or making subawards to parties that are suspended or debarred. Entities must verify vendor eligibility and retain documentation of the verification process for covered transactions of $25,000 or more. Condition: During our testing over suspension and debarment, we noted that PFI did not maintain documentation evidencing that suspension and debarment checks were performed for vendors receiving Federal funds. Cause: PFI does not have a formal policy with respect to retaining written documentation to evidence suspension and debarment reviews for vendors receiving Federal funds. Effect or Potential Effect: Failure to screen, in a timely manner (before contract date or payment occurs) potential and current vendors, suppliers, contractors and employees increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None. Context: 2 of 2 covered transactions selected for testing under 19.901 and 1 of 1 covered transactions selected for testing under ALN 81.113 had no written documentation to evidence that a suspension and debarment check was performed. Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. All screenings should be conducted prior to entering into an agreement with a vendor. Additionally, evidence of documentation should include the date of when the SAM check was performed. We recommend that PFI notify all employees of this policy and ensure that it is enforced during the upcoming year.