Finding Text
Federal Program: ALN 93.600 Head Start Program ALN 10.536 CACFP Training Grants Category: Compliance/ internal control significant deficiency Compliance requirements: Procurement and Suspension/Debarment Condition: BGCPR did not document or maintain evidence of the required SAM.gov vendor eligibility verifications for procurement transactions charged to federal programs. Criteria: Pursuant to 2 CFR § 200.214 and 2 CFR § 180.300, recipients and subrecipients may not enter into covered transactions with parties that are debarred, suspended, or otherwise excluded from participation in Federal awards and must verify that vendors are not excluded or disqualified by checking SAM.gov exclusions, obtaining a certification, or including an appropriate contractual clause. BGCPR Fiscal Policies and Procedures, under the Cash Disbursements and Cash Allocations policies, require that all vendors be verified through the System for Award Management (SAM.gov) prior to establishing a commercial relationship and before disbursing funds. Cause: Although BGCPR's Fiscal Policies and Procedures require verification of vendors through SAM.gov prior to establishing a commercial relationship and before disbursing Federal funds, management did not consistently adhere to these established policies and procedures. As a result, vendor eligibility reviews were not performed or documented as required. Context: For 17 of 21 transactions tested, BGCPR did not perform or maintain documentation evidencing that vendors were verified through SAM.gov prior to entering into covered transactions, as required by Federal regulations. Consequently, BGCPR could not demonstrate that the vendors were not suspended, debarred, or otherwise excluded from participation in Federal programs at the time the transactions were executed. Questioned cost: None identified. During our audit procedures, we found no evidence indicating that the vendors tested were suspended, debarred, or otherwise excluded from participation in Federal programs. However, because the required verification was not performed or documented at the time of the transactions, compliance could not be demonstrated. Effect or potential effect: The failure to perform and document SAM.gov searches increase the risk that federal funds could be expended on transactions with vendors that are suspended, debarred, or otherwise excluded from participation in federal programs, resulting in noncompliance with federal procurement requirements. Recommendation: We recommend that management strengthen its procurement policies and procedures to require documented verification of all applicable vendors through SAM.gov before awarding contracts or making purchases with federal funds. Evidence of the verification should be retained in the procurement file and periodically monitored for compliance. Views of officials responsible: We acknowledge that internal control should be strengthened by reviewing the current BGCPR Fiscal Policy, and effective September 30, 2026, all vendors must be verified who are not excluded or disqualified at System for Award Management (SAM.gov). This verification will be incorporated into the Workflow system and maintained as part of the vendor approval process. Anticipated completion date: September 30, 2026