Finding Text
Criteria: According to 2 CFR Section 180.300, 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, debarred or otherwise excluded. Condition: The District had transactions in excess of $25,000 with one vendor that they did not check for suspension and debarment or have a signed certification. Questioned Costs: None. Context: Total payments to the vendor were $110,248 as of June 30, 2022. Effect: The District was at risk of making material payments to vendors who are not allowed to do business with the federal government. There was no noncompliance, but there was no internal control in place to prevent noncompliance. Cause: The District was not aware of this requirement. Recommendation: We recommend the District check the Excluded Parties List System or collect certifications from the entity for any vendor that the District expects to pay more than $25,000 for the year. Management's Response: We were not aware of this requirement, but we will ensure that we comply going forward.