Finding Text
Procurement, Suspension & Debarment Criteria – Title 2 U.S. Code of Federal Regulations (CFR) §180.300 requires non-Federal entities entering into covered transactions with lower-tier participants to verify that the entity is not suspended, debarred, or otherwise excluded from participating in Federal programs. Condition – The Utility did not verify whether vendors paid with Federal funds were suspended or debarred prior to entering into covered transactions. Cause – The Utility’s management was not aware of the requirement to verify vendors and contractors were not suspended or debarred from participating in federally funded programs. Effect – The Utility did not maintain documentation demonstrating compliance with Federal procurement requirements related to suspension and debarment. As a result, the Utility was not in compliance with Uniform Guidance procurement requirements. Recommendation – We recommend the Utility establish procedures to verify that vendors and contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from participation in Federal programs. Verification should be performed through the System for Award Management (SAM) Exclusions website at SAM.gov and documentation of the verification should be retained. Response and Corrective Action Planned – The Utility is implementing procedures to verify vendors and contractors are not suspended or debarred by reviewing the SAM Exclusions listing available at SAM.gov and retaining documentation of the verification. Conclusion – Response accepted.