Finding Text
Finding 2025-004: Non-Compliance with Suspension and Debarment (Significant Deficiency) Federal Agency: National Institute of Health Federal Program: All of Us Research Program Assistance Listing Number: 93.368 Criteria: 2 CFR §200.213 non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business with, is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted as this compliance requirement is an administrative reporting requirement that does not impact cost eligibility. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Refer to Finding 2024-004. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date on which they were conducted.