Finding Text
Finding Number: 2025-001 Information on the Federal Program: Federal Agency: United States Department of Health and Human Services Program Name: National Center on Restorative Justice Assistance Listing Number: 16.030 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 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, the institution must verify that the vendor and/or employee 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), or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted that management did not review the SAM for employees meeting the covered transaction threshold. Context: We noted there were two employees exceeding $25,000 funded by the program. Based on our testing, neither of the employees exceeding the $25,000 limit were included in the SAM and received payments funded by the School’s major programs. Questioned Costs: None. Cause and Effect: The School was aware of the requirement to verify subrecipients against the SAM but was not aware that the requirement applied to employees. Since this process was not performed, there is a greater risk of employees that are included on the SAM being disbursed funds through federal funds. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the School follow established procedures for comparing employees against the SAM and 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 on page 44.