Finding Text
Finding 2024-001 – Procurement, suspension and debarment Assistance listing#: 14.267 Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000. A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person. Condition: During fiscal year 2024, MSP contracted with several vendors for products and services who were paid more than $25,000. There was no evidence documenting that these vendors were checked for suspension and debarment prior to payment. Cause: Although there were no individual services greater than $25,000, there were several vendors who were paid cumulatively more than $25,000. Most of these payments related to payments to client landlords. Per inquiry, the suspension and debarment status of these vendors was not checked during the fiscal year 2024. Effect: Without verifying whether vendors are suspended or debarred prior to payment, MSP faces a heightened risk that they are expending federal dollars to excluded parties. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend MSP perform and document each verification on vendors over $25,000 prior to funds being disbursed. An alternative would be for the standard contract to address suspension and debarment and obtain the certification from the vendors at the time the contract is executed. Additionally, we recommend that MSP’s policies and procedures be updated to reflect the need to check vendors for suspension and debarment on an annual basis. Response: MSP now performs and documents verification on all vendors and subcontractors. This practice has been implemented prior to the completion of the FY 2024 audit. Additionally, policies and procedures have been updated to reflect appropriate suspension and debarment considerations.