Finding Text
Finding 2025-002 Assistance Listing Number(s): 81.135 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Energy Federal Award Identification Number: DE-AR0001838 Federal Award Year: 2024 Award Period: March 26, 2024 through September 25, 2025 Criteria or Specific Requirement: 2 CFR §200.214 requires non-Federal entities to comply with 2 CFR Part 180 regarding suspension and debarment. Under 2 CFR §180.300, non-Federal entities must not enter into a covered transaction with a party that is suspended, debarred, or otherwise excluded from participation in Federal programs. The requirements contemplate verification of eligibility before entering into a covered transaction. Documentation supporting the verification should be retained in accordance with the Federal award's applicable record-retention requirements. Condition: Convergent Research did not document that suspension and debarment verification was performed prior to entering into covered transactions. Based on inquiry with management and review of the procurement files, Convergent Research did not perform or retain evidence of a SAM.gov exclusion verification before entering into agreements. Subsequent SAM.gov searches were performed during the audit, and did not identify the vendors as currently excluded. Cause: Management indicated that suspension and debarment verification was not incorporated into the procurement process at the time the agreements were executed. Consequently, the procurement files did not contain contemporaneous evidence demonstrating that the vendors' exclusion status had been verified before award. Effect or Potential Effect: Because Convergent Research did not document the required pre-award verification, it could not demonstrate from its procurement records that it had complied with the suspension and debarment requirements applicable to these covered transactions at the time of award. Although subsequent SAM.gov searches did not identify current exclusions, those searches occurred after the respective agreements were executed and therefore do not establish that the required verification was performed before the transactions were entered into. We did not identify evidence that covered transactions were actually suspended, debarred, or otherwise excluded at the time of award. Accordingly, the finding relates to the absence of documented verification, rather than evidence that Convergent Research entered into a covered transaction with an excluded party. Questioned Costs: None Repeat Finding: No Recommendation: We recommend that Convergent Research strengthen its procurement controls to require documented suspension and debarment verification before execution of all applicable covered transactions. The documentation should identify the vendor, date of verification, source used to perform the verification, and result of the search and should be retained in the procurement file. Views of Responsible Officials: Management agrees with the auditor’s recommendation and has incorporated required suspension and debarment verification into its federal grant procurement workflow, with documentation retained in the procurement file.