Core Issue: Key personnel failed to verify if vendors were debarred or suspended from federal programs.
Impacted Requirements: Procedures for validating vendor eligibility under federal program guidelines were not followed.
Recommended Follow-Up: Implement effective supervision and formal procedures to ensure compliance during vendor selection.
Finding Text
Condition: The key personnel in-charge of completing the procedures regarding eligibility of applicants under programs requirements did not perform the procedures to validate that the person or entity with whom it is intended to do business was not debarred, suspended or otherwise excluded from or ineligible for participation in Federal programs or activities. Cause: Lack of effective supervision procedures on contracts related to goods and services acquired with federal funds to ensure the personnel perform the required tasks during the purchase process. Effect or potential effect: Lack of formal procedures to ensure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost.
Corrective Action Plan
Responsibility for Suspension and Debarment compliance has been formally assigned to the Legal Affairs Division. The Legal Affairs Division is responsible for performing and documenting reviews of contractor eligibility, including verification through SAM and other applicable federal sources, prior to contract execution and when otherwise required by federal regulations.