Finding Text
SECTION III - FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS Finding Number: 2022-004 Repeat Finding: Similar to prior year federal awards finding 2021-003 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A19AV00866 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement, Suspension and Debarment Criteria: 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/Context: For five of 8 procurements over $25,000 tested, the School did not maintain documentation to support that a current suspension and debarment check was performed. Effect: Noncompliance with grant requirements. Cause: Lack of training, management turnover 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. Response: The School concurs with this recommendation and will implement procedures to ensure compliance with grant requirements. Contact person: Frances Stevens, Business Manager