Finding Text
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual,
corporation, association, unit of government, or legal entity, however organized) they are entering into a
covered transaction with is not suspended or debarred 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: Verification that an entity was not suspended or debarred was not performed timely for one
entity.
Context: The University entered into covered transactions with five entities during the fiscal year. We
selected a non-statistical sample of two entities for testing, noting verification that the entity was not
suspended or debarred was not performed timely for one entity. The procurement occurred in
September 2022, however, the verification that the entity was not suspended or debarred was not performed
until August 2023. We reviewed the subsequent verification and noted the entity did not have any exclusion
records, indicating they were not suspended or debarred.
Cause: Although the University has established policies and procedures in place over the procurement and
suspension and debarment process, there was a lack of diligence in complying with the policies and
procedures.
Effect: Failure to perform required verification procedures could result in noncompliance with the
procurement and suspension and debarment requirement.
Questioned Costs: None Identification of a repeat finding: N/A.
Recommendations: We recommend the University follow their procurement policies and procedures for
purchases using federal funds and perform the required procurement procedures in a timely manner.
Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the
departments to ensure that the required procedure for verification of Suspension and Debarment is
conducted timely. The Office of Sponsored Projects will strengthen its procedures so that verification from
SAM is obtained prior to confirming procurement, as is required by existing policy. The Principal
Investigator will work collaboratively with the Office of Sponsored Projects to ensure that the
documentation is obtained in a timely manner. The Manager for Grants and Contracts will timely check
SAM.gov for Suspension and Debarment and will maintain the documentation as required. The Assistant
Vice President overseeing the Office of Sponsored Projects will review the documentation and ensure
compliance with this requirement.