Core Issue: The Organization failed to verify that all vendors were eligible for federal funds, as required by 2 CFR ?180.300.
Impacted Requirements: Verification against the Excluded Parties List System was not consistently performed for vendors.
Recommended Follow-up: Update policies to ensure all vendors are confirmed as eligible for federal funding before transactions.
Finding Text
Finding 2022-012 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?180.300 mandates that 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. Condition and Context: The Organization did perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System. Cause and Effect: The Organization does not have internal processes to properly identify excluded parties not eligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties. Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Corrective Action Plan
Our Katahdin will properly verify all vendors are not included on the Excluded Parties List System going forward and document and retain this verification. Responsible official: Nancy DeWitt, Treasurer (207) 618-9187 Expected completion date: October 31, 2023