Finding 12853 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-11-17

AI Summary

  • Core Issue: The Institute failed to verify vendor eligibility against the SAM before disbursing funds for transactions over $25,000.
  • Impacted Requirements: Compliance with 2 CFR, Part 200, which mandates checking for suspensions or debarments in federally funded transactions.
  • Recommended Follow-Up: Establish a policy to ensure verification of vendor eligibility occurs prior to funding disbursement.

Finding Text

Program Affected AL Number 21.027 Coronavirus State and Local Fiscal Recovery Funds, passed through the Maine Department of Economic and Community Development, agreement period February 28, 2022 - June 30, 2023. Criteria Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, the institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), or by adding a clause or condition to the covered transaction. Condition and Context During our testing, we noted management did not review the SAM for beneficiaries meeting the covered transaction threshold prior to disbursing funding. Our nonstatistical sample of 40 transactions included 18 transactions equal to or exceeding $25,000. We understand the SAM was checked after the transactions were completed. Questioned Costs N/A Cause and Effect The Institute was unaware of the requirement to verify beneficiaries. Since this process was not performed, there is a greater risk of beneficiaries that are included on the SAM being disbursed funds through federal funds. Repeat Finding? No Recommendation We recommend that the Institute establish and follow a policy to confirm funds are not provided to those suspended or debarred in advance of the completed transaction. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.

Corrective Action Plan

Responsible Party: Gregory N. Lee, Director of Finance and Administration, Anticipated Completion Date: 11/30/2022; Subsequent to the funding of awards, management initiated a search of the SAM database of exclusions and found that no awardees were on that list. This was completed October 7, 2022. Future contracts for the award of federal funds will include a clause requiring a recipient to attest that they are not suspended or debarred from participating in transactions covered under the Federal Acquisition Regulation. Contracts will also indicate that the recipient consents to verification of all provided information. Management will also be undertaking a search of the SAM database of exclusions prior to the award of any funds. This step will be incorporated into the policies and procedures around the award approval process and staff will be provided with training to perform such a search.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 589295 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.66M
11.307 Economic Adjustment Assistance $403,950