Finding Text
Criteria: The Uniform Guidance (2 CFR 200.213) requires non-federal entities to ensure that federal funds are not awarded to or expended with parties that are suspended, debarred, or otherwise excluded. This requirement can be satisfied by obtaining a vendor certification or by checking the SAM.gov system prior to entering into covered transaction. Condition: We noted that the Organization did not perform or document required suspension and debarment checks for certain vendors and contractors paid with federal funds. The Organization did not obtain or retain evidence, such as a certification from the vendor or verification from the System for Award Management (SAM), to ensure the vendors were not suspended, debarred, or otherwise excluded from federal programs. Context: The Organization did not perform the suspension and debarment check. Cause: The Organization did not have an adequate procedures in place to ensure that suspension and debarment checks were consistently performed and documented. Questioned Costs: None Effect: Without performing suspension and debarment checks, the Organization risks expending federal funds on ineligible vendors, which could result in questioned costs and potential repayment of federal funds. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure suspension and debarment check are performed for all covered transactions and that evidence of such checks is retained in the procurrent files. Views of Responsible Officials (unaudited): The Organization agrees with the finding and recommendation. The Board of Directors of the Organization will develop policies and procedures to ensure they meet the Uniform Guidance Requirements.