Finding Text
Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Federal Award Identification Number and Year: 15POVC23GG00443ASSI-2024 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2024-AMS-077 Award Period: 10/01/2023 to 09/30/2025 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing we noted the Organization does not have formal suspension and debarment procedures. Questioned Costs: N/A Context: One of the one selections did not have any suspension/debarment procedures followed until after entering into the covered transaction as the policy in place only requires the search be performed. Cause: Management was aware of the suspension and debarment requirements dictated by the Uniform Guidance; however, the client's policy is not formally documented and does not include a required time frame. Effect: Potential for the Organization to do business with entities that are suspended or debarred which is not allowed per Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement a formal internal control policy over the suspension and debarment rules and follow them before entering into a covered transaction with another entity. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement and follow a suspension and debarment policy in accordance with 2 CFR section 180.995 and specify the review of a vendor must be done prior to entering into a covered transaction.