Finding Text
2021-001 - Procurement, Suspension and Debarment (Significant Deficiency)
Condition:
During our testwork over procurement, we noted that there were no procurement policy and payments made to vendors before checking suspension or debarment status on www.sam.gov.
Criteria:
Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: §200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Cause:
DSAL did not establish adequate internal controls and procedures and procurement policy to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards.
Effect:
DSAL is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require DSAL to reimburse the program for improper grant distributions.
Auditor's Recommendation:
We recommend that DSAL establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants.
Management Response:
Management agrees with the findings and has provided the accompanying corrective action plan.
Estimated Completion Date:
November 20, 2022
Responsible Party:
Patrick Eiser - DSAL Operations Director