Finding 1456 (2022-003)

2022-003 Suspension and Debarment Policy Program: N/A Criteria: In 2 CFR Part 180, the Uniform Guidance requires that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded. Condition: While The Center has a policy in place to ensure that its Board members and employees are not suspended, debarred, or otherwise excluded, it does not perform a review for vendors and landlords which may participate in covered transactions. Cause: Certain contracts specify that The Center perform debarment and exclusion checks monthly on all Board members and employees, but do not explicitly state that other parties should also be reviewed. Effect: Without reviewing vendors and landlords for suspension or debarment, there exists the possibility that The Center entered into covered transactions with excluded parties. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: The audit did not identify any transactions with suspended, debarred, or otherwise excluded parties. Repeat Finding: Yes; 2021-004. Recommendation: The Center should expand the current suspension and debarment policy to include review of vendors and landlords. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.