Finding Text
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Federal Programs. U.S Department of Education - Childcare Access Means Parents in School (CCAMPIS) (ALN 84.335A); Direct Award. U.S Department of Treasury - Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027); Passed through MiLEAP; ADN - BSN Completion Grant Program; Award Number SLFRP0127. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our review of procurement transactions, we noted that the College did not verify or document that vendors were not suspended or debarred at the time of contract execution or payment. Specifically, the procurement files reviewed lacked evidence demonstrating that vendor eligibility was confirmed through SAM.gov or an equivalent verification process in accordance with federal requirements at the time the College entered into the covered transaction. Cause. The condition resulted from inadequate internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the College to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. No costs were questioned related to this finding. Recommendation. We recommend the College review its procedures for issuing contracts to ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor to ensure compliance. View of Responsible Officials. Management agrees with finding and has prepared a corrective action plan.