Finding Text
Finding 2025-005 – Procurement and Suspension and Debarment: Retention of Debarment Checks – Noncompliance and Significant Deficiency in Internal Control Over Compliance; Agencies – Department of Health and Human Services, National Science Foundation, National Aeronautics and Space Administration, Department of Agriculture; Assistance Listing Numbers (ALN) - 93.859, 47.083, 47.050, 93.310, 43.008, 10.699, 47.078; Program Name - Research and Development Cluster; Award Year / Award Number – FY 2025, 2024, 2023, 2022, 2021, 2020 / Awards ANTHC- 23-U-396186; 5U24GM146576-02; 2049596; 2243258; ICER 2040729, Subaward 15660316; FIAN 2220560; ICER 1928230; Subaward 1558528; ICER 2052107; 2127346; 2309480; 80NSSC20M0070; 80NSSXC20M0070; 80NSSC24M0179, 24-MIRO-0054;1333MF4P0220; 18-JV-11261944-100; 2325081; 2419971, subaward 24-S37; Criteria or Specific Requirement – 2 CFR 200.214 prohibits recipients of federal awards from entering into contracts or other covered transactions with parties that are debarred, suspended, or otherwise excluded from participation in federal programs. Therefore, internal controls should be designed and implemented to provide reasonable assurance that an entity with which Alaska Pacific University plans to enter into a covered transaction is not debarred, suspended or otherwise excluded for covered transactions under Uniform Guidance.; Condition – APU did not retain evidence that vendor exclusion status was verified before contracts were executed.; Cause – Management did not have a formal process to verify and retain documentation of vendor suspension and debarment status for covered transactions under the Uniform Guidance.; Effect or Potential Effect – Management could enter into a covered transaction with a vendor that is debarred, suspended, or otherwise excluded.; Questioned Costs – None reported.; Context – We selected three procurements totaling $267,870 out of a total of 5 procurements totaling $369,307 made during the year. Documentation regarding vendor’s suspension, debarment, or other exclusion status was not retained on any of the selections tested.; Repeat Finding – This is not a repeat finding.; Recommendation - We recommend that management establish procedures requiring suspension and debarment checks to be completed before entering into covered transactions under federal awards. Documentation of the verification, such as SAM.gov search results, vendor certifications, or applicable contract provisions, should be retained in the procurement file.; Views of Responsible Officials – Management concurs with the finding and is implementing procedures to document and retain required verification.