Finding 1237647 (2025-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-28
Audit: 412567
Organization: Walker Basin Conservancy (CA)

AI Summary

  • Core Issue: WBC failed to verify the suspension or debarment status for one of six vendors, risking compliance with federal regulations.
  • Impacted Requirements: This finding relates to compliance with 2 CFR 200.403(a), which mandates verification of vendor status in covered transactions.
  • Recommended Follow-Up: WBC should enhance its policies to ensure timely verification of suspension and debarment status for all vendors as per procurement guidelines.

Finding Text

Federal Agency: U.S. Department of the Interior - BOR Federal Program Name: Providing Water to At-Risk Natural Desert Terminal Lakes Assistance Listing Number: 15.508 Federal Award Identification Year: 2025 Pass-Through Agency: National Fish and Wildlife Foundation Award Period: 7/1/19-10/31/25 Compliance Requirement Affected: Suspension and Debarment Type of Finding and other matters: Significant Deficiency in Internal Control over Compliance and other matters Criteria: 2 CFR 200.403(a) - 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 section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Of the six procured vendors that were selected, verification of subrecipient's suspension or debarment status was not performed for one vendor. Context: A nonstatistical sample of 6 out of 19 procured vendors were selected for testing for the above program. The condition noted above was identified during our procedures over WBC's procured vendors. Effect: WBC did not verify suspension or debarment status timely, which could result in procuring a vendor which is potentially suspended or debarred. Cause: WBC did not consistently ensure that Suspension or Debarment status was verified timely before naming procuring the vendor. Repeat Finding: The finding is a repeat finding. Recommendation: We recommend that WBC strengthen its current policies and procedures to ensure that Suspension and Debarment Status is verified for each vendor subject to verification of suspension and debarment verification according to WBC's Procurement policy. Management’s Views: See Separate Corrective Action Plan.

Corrective Action Plan

Finding 2025-006 Suspension and Debarment status verification (Vendors) U.S. Department of the Interior – BOR Providing Water to At-Risk Natural Desert Terminal Lakes – Assistance Listing No. 15.508 Recommendation: We recommend that WBC strengthen its current policies and procedures to ensure that Suspension and Debarment Status is verified for each vendor subject to verification of suspension and debarment verification according to WBC's Procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Plan: The Conservancy performed a complete review of ALL vendors to ensure all required vendors were verified for suspension and debarment status. That audit supported the facts that the Conservancy has never made a payment to a vendor with a suspension or debarment status. The Conservancy has revised its procurement forms and process to proactively include suspension and debarment status verification on all required vendors according to financial policies. Name(s) of the contact person(s) responsible for corrective action: Peter Stanton Planned completion date for corrective action plan: October 2025.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1237648 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.508 Providing Water to At-Risk Natural Desert Terminal Lakes $3.52M
15.237 Rangeland Resource Management $290,478
15.245 Plant Conservation and Restoration Management $169,516
15.808 U.S. Geological Survey Research and Data Collection $108,995
15.246 Threatened and Endangered Species $101,314
15.611 Wildlife Restoration and Basic Hunter Education and Safety $90,959
15.660 Endangered Species - Candidate Conservation Action Funds $88,753
15.554 Cooperative Watershed Management $72,826
15.247 Wildlife Resource Management $48,174
10.724 Sierra Front Wildfire Crisis Strategy Landscape Fuels and Vegetation Management $41,132
15.631 Partners for Fish and Wildlife $29,646
94.006 AmeriCorps State and National $7,086
10.890 Rural Development Cooperative Agreement $1,164
66.640 Nonpoint Source (NPS) 319(h) C9-97908122 $546