Finding 1172805 (2025-001)

Criteria – In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Nonfederal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition – During our review of procurement, suspension, and debarment compliance requirements for the selected vendor sample, we observed that while management conducted a suspension and debarment check prior to contracting with the vendor, documentary evidence of this check was not retained. Although management has maintained an ongoing working relationship with this vendor over several years and indicated that the required check was performed, they were unable to provide documentation confirming that the check was completed at the time the most recent contract was executed on April 1, 2025. Cause – The Organization’s current policies, procedures, and internal controls do not require the retention of documentation evidencing that suspension and debarment checks have been performed. Effect – Failure to retain documentation verifying that a vendor is not suspended or debarred may result in inadvertently entering into a contract without proper assurance that the vendor is eligible to participate, increasing the risk of noncompliance with suspension and debarment requirements. Questioned Costs – There are no known or likely questioned costs. Context – This is a condition identified per review of the Organization’s compliance with specified requirements of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that management continue to perform suspension and debarment checks prior to executing each covered transaction and retain appropriate documentation to evidence that these checks have been completed. Views of Responsible Officials – Management agrees with the finding. Please see appendix A for Management’s Corrective Action Plan.