Finding Text
2026-001 Suspension and Debarment Program Information Federal Agency U.S. Department of Health and Human Services Assistance Listing Numbers 93.493 Congressionally Directives Award Numbers 1 CE2CS54401‐01‐00 Criteria Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transaction (procurement contracts, purchase orders, or agreements greater than or equal to $25,000) with persons or vendors. [ ] Compliance Finding [X ] Significant Deficiency [ ] Material Weakness Condition The Organization did not retain written evidence for its verification on SAM.gov for its Vendors. Cause The Organization did not follow its policy to document its verification that persons or entities contracted with were not listed on the exclusions list prior to entering into the contracts or purchase agreements. Effect The Organization does not have evidence its covered transactions are not with persons who have been suspended or debarred. Questioned Costs None noted. Context We sampled one of three vendors used in covered transactions for which the Organization did not retain evidence that an exclusion check was performed prior to signing the contract. Exclusions checks were performed after documentation was requested, and no excluded vendors were identified. Recommendation We recommend the Organization implement controls requiring that evidence of exclusion checks be retained prior to signing any contracts or purchase orders or agreements that are covered transactions. Views of responsible officials and planned corrective action Management agrees with the auditor’s narrative associated with Finding 2026-001. It has consistently been the Organization’s policy to verify that vendors and contractors are not suspended or debarred by checking SAM.gov prior to engagement. However, management acknowledges that written verification/documentation of these checks was not formally retained in the project files prior to entering into contracts.