Finding Text
Federal Agency: Department of Agriculture; Department of Labor Federal Program Name: Supplemental Nutrition Assistance Program; National Dislocated Workers Grants Assistance Listing Number: 10.561 and 17.277 Pass-Through Agencies: (10.561) Illinois Department of Human Services, Maryland Statement Department of Human Services and Local Initiatives Support Corporation; (17.261) University of Rhode Island Research Foundation DBA Polaris MEP Pass-Through Numbers: (10.561) FCSCG06493; FIA/JARC 24-002; 40606-0107; (17.277) IG4-05-CON17 Award Period: (10.561) July 1, 2024 through June 30, 2025; October 1, 2023 through September 30, 2026; October 1, 2023 through September 30, 2024; (17.277) January 1, 2024 through December 31, 2024 Type of Finding: Other Matters Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions that are suspended or debarred. Before entering a covered transaction, the entity must verify that the contractor is not suspended, debarred, or otherwise excluded from participating in the transaction. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure vendors were not suspended or debarred. The Organization did not retain documentation that the suspension and debarment status of contractors were verified prior to entering the contract. Questioned costs: None Context: During our testing, it was noted that five of the five items were not reviewed to ensure the contractor’s suspension and debarment status was documented. Cause: The Organization’s controls were not sufficient to ensure that contractors’ suspension and debarment status was documented prior to entering the contract or saved at the time the contract was executed. Effect: The Organization could have entered into an agreement with a contractor that was suspended or debarred. Although the Organization was able to demonstrate that contracts were not entered into with vendors who were suspended or debarred, the absence of documentation performed prior to contract execution presents a risk of noncompliance with applicable procurement regulations. Repeat Finding: Yes. See prior year finding 2023-001 Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred prior to entering transactions with contractors. This verification may be accomplished by: 1. Check the System for Award Management (SAM) Exclusions and save verification 2. Collecting a certification form, or 3. Adding a clause or condition to the covered transaction with that entity. Views of responsible officials: There is no disagreement with the audit finding.