Finding Text
Information on Federal Program: Assistance Listing Numbers 93.914 and 93.917
Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific requirements
on screening of all potential and current vendors, suppliers, contractors, subrecipients, employees,
fellows, etc. to ensure the recipient is not conducting business with excluded parties (as defined by the
United States Government). This screening process must also be documented in writing.
Condition: UHU did not consistently perform the screening process for its potential and current
vendors, suppliers, contractors, subrecipients, employees, etc. that were paid with Federal funds.
Context: Payments were made during the fiscal year without performing the proper screening process.
Our audit work in this area consisted of internal control testwork over a random sample of expenditures,
as well as substantive testwork over transactions above a defined threshold from select expense
accounts that were charged to the Federal program. The issue is deemed to be systemic. Cause: UHU did not have a formal policy in place with regard to suspension and debarment
screenings, although they did occasionally perform screening of potential and current vendors,
suppliers, contractors, subrecipients, and employees.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: Undetermined
Identification of Repeat Finding: 2020-005
Recommendation: We recommend UHU establish policies and ensure that all types of parties (as
noted above) are included, and educate its employees on the procedures necessary to ensure full
compliance with this requirement. We also recommend that UHU document each of these screenings
and retain them in the respective files, which should be completed prior to engaging in relationships with
these parties. For ongoing relationships, UHU should consider performing screenings on an annual
basis (and documenting them) to ensure continuous compliance in the event the suspension and
debarment status of any of these parties changes. Lastly, we recommend UHU perform retrospective
screenings on these parties to which it made payments during the fiscal year.