FAC Explorer

Finding 1169315 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-01-16
Audit: 382265
Organization: Yale University (CT)
Auditor: PRICEWATERHOUSECOOPERS LLP

AI Summary

  • Core Issue: Debarment checks were not consistently performed for new vendors before transactions, violating 2 CFR 200.214 requirements.
  • Impacted Requirements: Procedures for verifying vendor eligibility were not followed, leading to potential compliance risks.
  • Recommended Follow-Up: Provide additional training for staff on debarment checks and explore automating the vendor screening process.

Finding Text

2025-001 –Procurement, Suspension and Debarment Cluster / Program: Research & Development (R&D) / ALN 19.UO9, 19.U10: The MITRE Corporation – U.S. Department of State Grantor: - Defense Advanced Research Projects Agency (DARPA) / DoD, National Science Foundation (NSF) / U.S. Department of State Award Name: EE Tang MPI PennST DARPA Monolithic GaN, Social Networks and Migration in Nepal / Conflict Observatory – Sudan, Conflict Observatory – Ukraine Award Number: AWD0011529, AWD0007921 / AWD0011946, AWD0010905 Award Year: FY2025 Assistance Listing Numbers: 12.910, 47.075 / 19.U09, 19.U10 Assistance Listing Titles: Research and Technology Development, Social, Behavioral, and Economic Sciences / U.S Department of State Pass-Through Entities: N/A / Pennsylvania State University Criteria Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the transaction. Condition We selected a sample of 25 transactions within the R&D cluster and 5 transactions within ALN 19.U09, 19.U10 and noted two selections within R&D cluster and one selection within ALN 19.U09, 19.U10 where debarment checks were not performed prior to entering into the transaction. Cause Due to the manual nature of the debarment checks, there was an oversight and the vendors were not screened at the time of set up due to human error. Effect New vendors are not consistently checked for suspension and debarment prior to the University entering into a transaction with the vendors as required by the regulation stated above. Questioned Costs None noted. Repeat Finding in the Prior Year No Recommendation PwC recommends additional training for employees responsible for suspension and debarment checks to ensure established procedures are followed when entering into a covered transaction with an entity. Additionally, we recommend considering an automated process where when a new vendor is entered into the system, a debarment check is automatically initiated.

Corrective Action Plan

Views of Responsible Officials and Corrective Action Plan 2025-001 –Procurement, Suspension and Debarment Cluster / Program: Research & Development (R&D) / ALN 19.UO9, 19.U10: The MITRE Corporation – U.S. Department of State Grantor: - Defense Advanced Research Projects Agency (DARPA) / DoD, National Science Foundation (NSF) / U.S. Department of State Award Name: EE Tang MPI PennST DARPA Monolithic GaN, Social Networks and Migration in Nepal / Conflict Observatory – Sudan, Conflict Observatory – Ukraine Award Number: AWD0011529, AWD0007921 / AWD0011946, AWD0010905 Award Year: FY2025 Assistance Listing Numbers: 12.910, 47.075 / 19.U09, 19.U10 Assistance Listing Titles: Research and Technology Development, Social, Behavioral, and Economic Sciences / U.S Department of State Pass-Through Entities: N/A / Pennsylvania State University The University acknowledges the need for consistent application of policies and procedures to ensure compliance with 2 CFR 200.214. The university performed a root cause analysis and determined that these identified issues were human error due to the manual nature of the established process. The University reviewed the three identified vendors and concluded that they were not debarred at the time of the transaction. Outlined below are steps that the university will take or have taken to improve our processes and procedures:  As of June 2025, Yale has implemented the Supplier Gateway Portal, introducing an enhanced, automated process for supplier onboarding. New suppliers established through the portal are automatically screened for debarment without manual involvement. Subsequently, the supplier’s information is transferred weekly to the Visual Compliance system, which performs continuous debarment monitoring. Yale is proactively notified via email should any changes in a supplier's status occur.  The university provided training to the full team responsible for these activities with the rollout of the Supplier Gateway Portal. This was completed June 2025. University contact: Rodney Brunson, Director, Accounts Payable & Payment Services Rodney.Brunson@yale.edu

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1169312 2025-001
    Material Weakness Repeat
  • 1169313 2025-001
    Material Weakness Repeat
  • 1169314 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $76.22M
84.063 Federal Pell Grant Program $10.24M
47.076 Education and Human Resources $5.40M
81.RD Department of Energy $3.43M
19.U10 U.S Department of State $2.69M
84.038 Federal Perkins Loan Program $2.68M
98.RD Agency for International Development $2.47M
93.989 International Research and Research Training $2.42M
93.859 Biomedical Research and Research Training $2.33M
93.384 Advanced Research Projects Agency for Health $2.00M
93.855 Allergy and Infectious Diseases Research $1.94M
84.033 Federal Work-Study Program $1.87M
93.242 Mental Health Research Grants $1.82M
84.007 Federal Supplemental Educational Opportunity Grants $1.50M
93.317 Emerging Infections Programs $1.45M
93.RD Department Of Health And Human Services $1.43M
93.558 Temporary Assistance for Needy Families $1.22M
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $1.15M
81.049 Office of Science Financial Assistance Program $1.00M
93.914 HIV Emergency Relief Project Grants $967,772
93.879 Medical Library Assistance $846,682
93.172 Human Genome Research $807,252
93.969 PPHF Geriatric Education Centers $788,779
10.937 Partnerships for Climate-Smart Commodities $742,456
12.800 Air Force Defense Research Sciences Program $719,446
93.364 NURSING STUDENT LOANS $711,721
93.732 Mental and Behavioral Health Education and Training Grants $691,585
93.866 Aging Research $673,178
93.123 Health Professions Pre-graduate Scholarship Program for Indians $603,186
12.910 Research and Technology Development $573,616
93.110 Maternal and Child Health Federal Consolidated Programs $521,967
93.396 Cancer Biology Research $514,570
84.305 Social and Behavioral Context for Academic Learning $513,859
93.865 Child Health and Human Development Extramural Research $496,338
12.RD Department of Defense $484,384
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $478,097
93.297 TEENAGE PREGNANCY PREVENTION PROGRAM $476,712
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $467,885
10.309 Specialty Crop Research Initiative $465,118
93.350 National Center for Advancing Translational Sciences $462,695
93.838 Lung Diseases Research $461,761
12.300 Basic and Applied Scientific Research $455,501
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $424,880
93.273 Alcohol Research Programs $418,069
12.750 Uniformed Services University Medical Research Projects $413,743
93.279 Drug Abuse and Addiction Research Programs $409,261
93.145 HIV-Related Training and Technical Assistance $401,438
12.431 Basic Scientific Research $373,928
93.393 Cancer Cause and Prevention Research $351,125
93.226 Research on Healthcare Costs, Quality and Outcomes $349,551
16.575 Crime Victim Assistance $340,034
10.250 Plant and Animal Disease, Pest Control, and Animal Care $325,119
93.837 Cardiovascular Diseases Research $317,045
93.838 Cardiovascular Diseases Research $315,685
43.001 Science $313,389
93.262 Occupational Safety and Health Program $311,011
93.307 Minority Health and Health Disparities Research $306,884
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $283,038
16.560 NATIONAL INSTITUTE OF JUSTICE RESEARCH, EVALUATION, AND DEVELOPMENT PROJECT GRANTS $282,673
84.015 National Resource Centers Program $278,900
93.233 National Center on Sleep Disorders Research $276,481
93.U07 Department Of Health And Human Services $266,071
47.084 Technology, Innovation and Partnerships $264,867
93.143 NIEHS Superfund Hazardous Substances_Basic Research and Education $250,697
12.420 Military Medical Research and Development $243,870
93.U06 Department Of Health And Human Services $234,583
47.041 Engineering Grants $232,270
47.049 Mathematical and Physical Sciences $219,897
93.394 Cancer Detection and Diagnosis Research $205,901
81.087 Renewable Energy Research and Development $205,106
93.310 Trans-NIH Research Support $203,649
98.U12 Agency for International Development $203,113
93.788 OPIOID STR $195,269
21.027 American Rescue Plan Act Funds $191,663
93.397 Cancer Centers Support Grants $191,615
93.967 CDC's Collaboration with Academia to Strengthen Public Health $191,148
93.354 COVID-19 PHEP Crisis Response $189,568
93.121 Oral Diseases and Disorders Research $188,389
93.940 HIV Prevention Activities_Health Department Based $187,650
66.RD Environmental Protection Agency $183,122
93.421 Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health $181,768
14.906 Healthy Homes Technical Studies Grants $177,242
47.078 Polar Programs $165,293
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $164,013
84.423 Supporting Effective Educator Development Program $156,798
93.213 Research and Training in Complementary and Integrative Health $156,542
10.310 Agriculture and Food Research Initiative (AFRI) $155,494
93.879 MEDICAL LIBRARY ASSISTANCE $152,306
47.074 Biological Sciences $151,515
19.019 International Programs to Combat Human Trafficking $150,268
93.433 ACL National Institute on Disability, Independent Living, and Rehabilitation Research $147,522
66.509 Science To Achieve Results (STAR) Research Program $142,850
93.867 Vision Research $138,509
47.070 Computer and Information Science and Engineering $137,715
93.070 Environmental Public Health and Emergency Response $137,434
93.361 Nursing Research $137,266
43.RD National Aeronautics & Space Administration $128,984
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $128,398
93.928 Special Projects of National Significance $126,480
93.516 Public Health Training Centers Program $125,950
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $124,634
10.215 Sustainable Agriculture Research and Education $121,979
81.135 ADVANCED RESEARCH PROJECTS AGENCY - ENERGY $120,720
93.859 Allergy and Infectious Diseases Research $120,465
93.395 Cancer Treatment Research $119,423
93.U05 Department Of Health And Human Services $115,444
93.113 Environmental Health $113,993
93.U02 Department Of Health And Human Services $108,864
93.575 Child Care and Development Block Grant $102,013
19.U09 U.S Department of State $100,394
93.304 Racial and Ethnic Approaches to Community Health $96,949
47.047 Scientific Research Project Support $92,554
93.884 Grants for Primary Care Training and Enhancement $91,868
12.335 Navy Command, Control, Communications, Computers, Intelligence, Surveillance, and Reconnaissance $89,447
93.351 Research Infrastructure Programs $86,241
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $85,748
93.313 NIH Office of Research on Women's Health $79,296
93.823 Ebola Support: Transmission and Prevention Control, Public Health Preparedness, Vaccine Development $78,427
47.079 Office of International Science and Engineering $75,239
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $74,191
81.086 Conservation Research and Development $71,612
43.012 Space Technology $69,408
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $64,488
45.312 National Leadership Grants $63,221
98.001 USAID Foreign Assistance for Programs Overseas $59,584
93.989 INTERNATIONAL RESEARCH AND RESEARCH TRAINING $58,472
93.U04 Department Of Health And Human Services $54,535
47.075 Social, Behavioral, and Economic Sciences $53,071
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION’S HEALTH $51,847
93.959 Block Grants for Prevention and Treatment of Substance Abuse $51,208
93.600 Head Start $49,799
45.301 Museums for America $48,607
47.RD National Science of Foundation $48,132
93.136 Injury Prevention and Control Research and State and Community Based Programs $47,733
12.U13 Department of Defense $47,505
11.431 Climate and Atmospheric Research $45,638
84.425 American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund $44,217
47.050 Geosciences $40,383
47.083 Office of Integrative Activities $39,756
43.003 Exploration $38,031
16.026 OVW Research and Evaluation Program $37,013
93.647 Social Services Research and Demonstration $34,141
84.425 Education Stabilization Fund $34,120
10.707 Research Joint Venture and Cost Reimbursable Agreements $33,252
93.243 Substance Abuse and Mental Health Services_Projects of Regional and National Significance $32,688
93.U03 Department Of Health And Human Services $30,525
10.174 Acer Access Development Program $30,300
12.400 Military Construction, National Guard $28,545
10.RD Department of Agriculture $26,692
45.024 PROMOTION OF THE ARTS GRANTS TO ORGANIZATIONS AND INDIVIDUALS $26,667
93.839 Blood Diseases and Resources Research $25,228
19.801 Office of Global Women's Issues $25,000
93.088 Advancing System Improvements for Key Issues in Women's Health $23,653
81.117 ENERGY EFFICIENCY AND RENEWABLE ENERGY INFORMATION DISSEMINATION, OUTREACH, TRAINING AND TECHNICAL ANALYSIS/ASSISTANCE $23,268
84.022 Fulbright-Hays Doctoral Dissertation Research Abroad (DDRA) Fellowship Program $20,690
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $20,216
93.068 Chronic Diseases: Research, Control, and Prevention $18,276
15.U08 Department of Interior $17,633
15.805 Assistance to State Water Resources Research Institutes $17,536
45.169 PROMOTION OF THE HUMANITIES OFFICE OF DIGITAL HUMANITIES $16,991
93.669 Child Abuse and Neglect State Grants $16,712
15.808 U.S. GEOLOGICAL SURVEY RESEARCH AND DATA COLLECTION $16,289
10.001 Agricultural Research_Basic and Applied Research $16,192
93.127 Emergency Medical Services for Children $15,092
93.173 Research Related to Deafness and Communication Disorders $14,157
66.U11 Environmental Protection Agency $13,101
93.185 IMMUNIZATION RESEARCH, DEMONSTRATION, PUBLIC INFORMATION AND EDUCATION TRAINING AND CLINICAL SKILLS IMPROVEMENT PROJECTS $12,499
93.399 Cancer Control $12,373
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $11,686
93.398 Cancer Research Manpower $10,596
10.674 Wood Utilization Assistance $10,485
10.U01 Department of Agriculture $9,809
93.117 Preventive Medicine and Public Health Residency Training Program, Integrative Medicine Program, and National Center for Integrative Primary Healthcare $9,341
66.604 Environmental Justice Small Grant Program $8,425
10.652 Forestry Research $8,109
93.103 Food and Drug Administration_Research $8,081
43.008 Education $7,300
93.247 Advanced Nursing Education Grant Program $5,360
93.424 NON-ACA/PPHF Building Capacity of the Public Health System to Improve Population Health through National Nonprofit Organizations $5,246
93.342 HEALTH PROFESSIONS STUDENT LOANS, INCLUDING PRIMARY CARE LOANS AND LOANS FOR DISADVANTAGED STUDENTS $3,158
93.268 Immunization Cooperative Agreements $2,664
66.312 Environmental Justice Government-to-Government (EJG2G) Program $2,509
93.665 Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 $2,411
45.161 PROMOTION OF THE HUMANITIES RESEARCH $164
19.RD U.S Department of State $-31,193