Finding Text
Criteria: In accordance with 2 CFR Part 180.300, non-federal entities are prohibited from entering into covered transactions with parties that are suspended or debarred from participation in federal programs. Internal controls should provide reasonable assurance that applicable subrecipients, contractors, and vendors are appropriately vetted before agreements are executed or federal funds are expended. Condition: The Organization had not established or documented procedures to verify whether any applicable subrecipients, contractors, and vendors were suspended or debarred. Management was unable to provide evidence that searches of SAM.gov or other permitted verification methods had been performed before entering into agreements or making federally funded payments. Cause: The Organization had not implemented formal policies requiring suspension and debarment verification or retention of supporting documentation. As a result, verification was performed informally and evidence of review was not retained. Effect: Testing did not identify any parties that were suspended or debarred, however, the absence of documented controls increases the risk that the Organization could enter into federally funded transactions with prohibited parties without timely detection. Questioned Costs: None noted Repeat Finding: No Recommendation: We recommend that management establish procedures to verify and document the suspension and debarment status of applicable subrecipients, contractors, and vendors before entering into agreements or expending federal funds. Evidence of SAM.gov searches or other permitted verification methods should be retained to demonstrate compliance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding; see corrective action plan.