Finding Text
2022-006 Procurement, Suspension, and Debarment (Significant Deficiency) - Repeated & Modified
(Prior Year Finding 2021-006)
Federal Program Information:
Funding Agency Title ALN # Award Year and Number
U.S. Department of Interior Indian School Equalization Program 15.042 2021 AI9AV00859
Criteria or Specific Requirement
Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered
transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2
CFR §180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the System
of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting
a certification from the entity or adding a clause or condition to the covered transaction with that entity (2
CFR §180.300).
Condition
During the testwork over procurement, we noted that for all three (3) transactions over $25,000 tested,
the School was unable to provide documentation showing that the procurement process was followed.
In addition, there was no documentation showing that the School had searched the respective vendor
on the System for Award Management (sam.gov) to ensure that the vendor was not suspended or
debarred.
Questioned Costs
The calculation of questioned costs was not determinable for these instances of noncompliance.
Cause
The School did not follow its policies and procedures regarding procurement, suspension, and
debarment.
Effect
Noncompliance with grant requirements.
Auditor's Recommendation
For procurements over $25,000, the School should implement policies and procedures that ensure
suspension and debarment checks are performed annually on required vendors.