Finding Text
Finding No. 2022-002 Significant Deficiency: Procurement, Suspension And Debarment ? Control Finding Federal Award Information: U.S. Department of Education, Special Education Cluster, passed through the Missouri Department of Elementary and Secondary Education ALN: 84.027 and 84.173 - Special Education Cluster Criteria: According to Uniform Guidance, 2 CFR Section 180.300, 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The District did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transaction with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: The District?s internal control over compliance did not operate effectively related to suspension and debarment. The District?s policy is to maintain evidence of the SAM verification for each vendor or contractor; however, there was no documentation maintained for the transactions selected for testing. Effect: The District could have entered into covered transaction with an entity that is suspended or debarred resulting in non-compliance with the compliance requirement. Questioned Costs: Not applicable. Context: An exception was noted in the two covered transactions sampled out of the population of seven. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification As A Repeat Finding: Yes. Recommendation: We recommend that the District adhere to its policy and maintain support that a SAM verification is performed prior to entering into contracts or covered transactions. Views Of Responsible Officials: The District will implement a process that requires a verification and the retention of that verification that the vendor is in good standing with the federal government prior to entering into a contract with the vendor. The District will also review the RFPs, RFQs, and grant related contracts to verify that proper documentation is retained.