Finding 1175403 (2025-007)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-02-25
Audit: 389114
Organization: Norwich University (VT)

AI Summary

  • Core Issue: The Organization lacks a process to verify that vendors and employees involved in federally funded transactions are not suspended or debarred.
  • Impacted Requirements: Compliance with 2 CFR, Part 200, which mandates checking the System for Award Management (SAM) for covered transactions exceeding $25,000.
  • Recommended Follow-Up: Establish a regular procedure to check vendors and employees against SAM and document these verifications, especially when new entries are made.

Finding Text

Finding Number: 2025-007 Federal Program: Federal Agency: U.S. Department of Defense, U.S. Department of Transportation, National Aeronautics and Space Administration, National Science Foundation, U.S. Department of Health and Human Services, and U.S. Department of the Interior Program Names: Research and Development Cluster and Congressionally-Identified Projects AL: 12,903, 12,905, 12,910, 20.701, 43.008, 47.076, 47.083, 93.310, 93.493, 93.859, and 11.617 Federal Award Identification Numbers: Various, refer to the SEFA Federal Award Year: 2025 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization does not currently have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. Context: We randomly selected, using a nonstatistical sample, 25 vendors and 40 employees funded by the award. None of the vendors or employees selected for testing were identified on SAM. Questioned Costs: None noted Cause and Effect: The Organization was not aware of the requirement to verify vendors and employees against SAM on a regular basis. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program by SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

The University did not have an internal control procedure designed to compare vendors and employees against the SAM database to ensure they were not suspended or disbarred. The University is implementing a quarterly review process to compare both employees and vendors against the SAM database. Responsible party: Susannah Naylor, Controller; snaylor1@norwich.edu Anticipated Completion Date: May 31, 2026

Categories

Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1175387 2025-006
    Material Weakness Repeat
  • 1175388 2025-006
    Material Weakness Repeat
  • 1175389 2025-007
    Material Weakness Repeat
  • 1175390 2025-007
    Material Weakness Repeat
  • 1175391 2025-007
    Material Weakness Repeat
  • 1175392 2025-007
    Material Weakness Repeat
  • 1175393 2025-007
    Material Weakness Repeat
  • 1175394 2025-007
    Material Weakness Repeat
  • 1175395 2025-007
    Material Weakness Repeat
  • 1175396 2025-007
    Material Weakness Repeat
  • 1175397 2025-007
    Material Weakness Repeat
  • 1175398 2025-007
    Material Weakness Repeat
  • 1175399 2025-007
    Material Weakness Repeat
  • 1175400 2025-007
    Material Weakness Repeat
  • 1175401 2025-007
    Material Weakness Repeat
  • 1175402 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $14.00M
84.063 FEDERAL PELL GRANT PROGRAM $4.41M
12.905 CYBERSECURITY CORE CURRICULUM $1.91M
11.617 CONGRESSIONALLY-IDENTIFIED PROJECTS $1.91M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $1.56M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.42M
93.310 TRANS-NIH RESEARCH SUPPORT $821,454
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $680,256
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $607,483
84.033 FEDERAL WORK-STUDY PROGRAM $411,687
93.364 NURSING STUDENT LOANS $137,062
20.701 UNIVERSITY TRANSPORTATION CENTERS PROGRAM $124,996
12.910 RESEARCH AND TECHNOLOGY DEVELOPMENT $89,874
81.008 CYBERSECURITY, ENERGY SECURITY & EMERGENCY RESPONSE (CESER) $62,515
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $49,772
15.814 NATIONAL GEOLOGICAL AND GEOPHYSICAL DATA PRESERVATION $32,635
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $22,808
93.493 CONGRESSIONAL DIRECTIVES $13,864
12.903 GENCYBER GRANTS PROGRAM $12,722
47.083 INTEGRATIVE ACTIVITIES $11,007
12.902 INFORMATION SECURITY GRANTS $6,965
93.859 Biomedical Research and Research Training $4,718