Finding Text
Criteria – When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR § 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. “Covered transactions” include those procurement contracts for goods and services awarded under non-procurement transactions (e.g. grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR § 180.220. This requirement applies to contracts entered into to procure goods and services with Individuals with Disabilities Education Act funds. Condition – Scituate School Department does not appear to have any specific procedures in place for verifying that an entity with which is plans to enter into a covered transaction is not suspended, debarred or otherwise excluded. Cause – The District’s controls over contracting with entities does not have an instituted procedure directing staff to ensure and confirm that the vendor is not suspended or debarred. Effect – It appears that contracts for goods or services that were “covered transactions” were entered into without verification that the vendor was not suspended, debarred or otherwise excluded. Questioned Costs – None Recommendation – We recommend that the District update its policies to incorporate verification procedures to ensure that an entity with which it plans to enter into a covered transaction is not suspended, debarred or otherwise excluded. Management’s Response – Management acknowledges the lack of suspension and debarment language in its procurement procedures in effect during FY25. Corrective Action: This issue was addressed and corrected in FY26. Specifically, the school department has implemented an updated procurement policy and procedure to meet the suspension and debarment requirement. We have provided training to staff and updated automated procurement approval chains to ensure compliance. Expected Completion: The corrective actions have been substantially completed as of this writing. Final completion expected by June 30, 2026.