Finding Text
Finding: 2023-002 Non-Compliance with Suspension and Debarment
Information on the Federal Program: Assistance Listing Number 16.582
Criteria: Under 2 CFR §200.213, 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. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a
certification from that person; or (c) Adding a clause or condition to the covered transaction with that
person.
Condition: The Association did not consistently perform screenings on its potential or current
vendors, suppliers, or contractors that were paid with Federal funds.
Cause: The Association does not have a formal policy with respect to screening vendors, suppliers,
or contractors in order to adhere to compliance over suspension and debarment.
Effect: Failure to screen potential and current vendors, suppliers, contractors, subrecipients, 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: None noted.
Context: Our audit procedures consisted of testwork completed on individual expenditures charged
to the Federal awards. The report in which samples were selected was generated directly from the
Association's accounting system. We consider our sample to be representative of the population. The
condition appeared to be systemic in nature.
Identification as a Repeat Finding: This is not a repeat finding.
Recommendation: We recommend management develop and implement a formal policy on
suspension and debarment. This policy should include a threshold, generally $25,000, for when
vendors, suppliers, contractors and sub-contractors/grantees should be screened. All screenings
should be conducted prior to signing a contract or issuing payment. We recommend that the
Association notify all employees of this policy and ensure that it is enforced during the upcoming
fiscal year.