Finding Text
Condition The Institute does not have a written procurement policy. Additionally, the Institute does not perform suspension and debarment verification (e.g., checking the System for Award Management (SAM.gov) or equivalent excluded parties list) prior to entering into contracts or agreements with vendors, contractors, or subrecipients. Criteria Organizations that receive federal funding are generally required, under 2 CFR § 200.318–200.327 (Uniform Guidance), to: • Maintain written procurement procedures that conform to applicable federal, state, and local laws; • Ensure procurement transactions are conducted in a manner providing full and open competition; • Verify that contractors and subrecipients are not suspended, debarred, or otherwise excluded from participating in federal programs, per 2 CFR § 200.214 and 2 CFR Part 180. Cause The Institute has not formalized its procurement practices in a written policy and staff is not currently required to check suspension and debarment status as part of the vendor selection or contracting process. Effect Without a written procurement policy, the Institute lacks a consistent, auditable standard for procurement decisions, increasing the risk of non-compliance, favoritism, or inconsistent practices across departments. The absence of suspension and debarment checks creates risk that the Institute could enter into agreements with parties who are legally excluded from receiving federal funds, potentially resulting in disallowed costs, reputational harm, or loss of funding. Recommendation The Institute should develop and formally adopt a written procurement policy that addresses methods of procurement, competition requirements, documentation standards, and conflict-of-interest provisions consistent with 2 CFR § 200.318–200.327. The Institute should also implement a documented procedure requiring suspension and debarment verification (via SAM.gov or equivalent) for all vendors, contractors, and subrecipients prior to contract execution, and retain evidence of this check in procurement files. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendation. The Institute is formalizing its procurement practices in a written procurement policy consistent with applicable Uniform Guidance requirements. The policy addresses procurement methods, competition, documentation, conflicts of interest, and suspension and debarment requirements for procurements in accordance with federal regulations. The Institute contracted with Visual Compliance to assist with verifying vendors against all available U.S. debarred and suspended lists before entering into covered contracts or agreements with vendors, contractors, or subrecipients. The Institute has developed and approved a Suspension and Debarment policy and staff are required to check suspension and debarment status as part of the vendor selection or contracting process. The Institute is developing a written procurement policy. Evidence of the verification will be retained with the applicable procurement or agreement documentation.