Finding Text
Finding 2025-002 – Suspension and Debarment Award information Cluster: N/A Grantor: U.S. Department of Energy Award name: Grid Infrastructure Deployment and Resilience Award number: DE-GD0000041 Award year: 2025 Assistance listing number: 81.254 Assistance listing title: Grid Resilience Grant Program 40101 (d) Pass-through entity: N/A Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (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 section 180.220. This verification may be accomplished by (1) checking the System for Award Management (SAM.gov) for exclusions, (2) collecting a certification from that person, or (3) adding a clause or condition to the covered transaction with that person (2 CFR section 180.300). Santee Cooper has established a Supplier Performance Policy that provides procedures for evaluating supplier performance and placing suppliers in Inactive, Non-Responsive, or Debarred status. The policy provides that suppliers may be debarred for certain convictions, failure to correct violations of contract provisions, or failure to perform as required under a contract. Condition In testing compliance with suspension and debarment requirements, we selected 2 transactions greater than $25,000 and noted that, for both transactions, Santee Cooper was unable to provide evidence that the vendors’ suspension and debarment status had been verified against the SAM.gov exclusions database or provide evidence of another permissible method of verifying that the vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into the covered transactions. Cause Santee Cooper’s policy establishes procedures for evaluating supplier performance and internally placing suppliers in Inactive, Non-Responsive, or Debarred status. However, the policy did not establish procedures requiring verification that suppliers are not suspended, debarred, or otherwise excluded from participation in federal programs through SAM.gov or another permissible verification method prior to entering into applicable covered transactions, as this requirement was not understood by management. Effect The lack of validation of the vendors against the required SAM.gov database (or allowed alternative) increases the risk that procurements could be made with suspended or debarred vendors. Questioned costs None noted. Recommendation We recommend Santee Cooper enhance its procedures to ensure suspension and debarment status is verified for applicable covered transactions prior to entering into the transaction and, as appropriate, periodically thereafter. Santee should also maintain sufficient documentation to demonstrate that an allowable verification method was performed, including evidence of the results of such verification. Repeat Finding from the Prior Year No Management’s views and corrective action plan Management’s view and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.