Finding Text
Finding 2023-002: Procurement, Suspension, and Debarment (Material Weakness)
Federal Program: Assistance Listing Number 14.267
Criterion or Specific Requirements: 2 CFR Section 200.318 requires that the non-Federal entity
must have and use documented procurement procedures, consistent with State, local, and tribal
laws and regulations and the standards of this section, for the acquisition of property or services
required under a Federal award or subaward. The non-Federal entity's documented procurement
procedures must conform to the procurement standards identified in §§ 200.317 through 200.327.
2 CFR Section 200.214 requires that, for covered transactions, a non-Federal entity must verify that
entities are not suspended, debarred or otherwise excluded. This verification may be accomplished
by checking the System for Award Management (SAM) website maintained by the General Services
Administration. Condition: IW has a formal written procurement policy, but it does not conform to the procurement
standards identified in §§ 200.317 through 200.327, which is the Uniform Guidance. As a result, no
procurement files were maintained to document IW's procurement actions. In addition, for all
disbursements tested, IW could not provide documentation of their verification, prior to payment, that
the vendors were not suspended, debarred or otherwise excluded.
Questioned Costs: None.
Cause: IW has not updated its written procurement policy to conform to the Uniform Guidance. In
addition, IW did not require that evidence of SAM checks be maintained in its vendor files. As a
result, IW did not maintain adequate support to provide evidence that appropriate suspension and
debarment searches were performed. Despite the lack of documentation, a search was performed
after the fact to verify that the vendors or individuals in our sample were not suspended, debarred or
otherwise excluded. Therefore, no questioned costs have been reported related to the sample that
was tested.
Effect or Potential Effect: Without an updated procurement policy that conforms to the Uniform
Guidance and related procurement documentation, there is a risk that IW did not perform a proper
evaluation of each potential vendor whose costs were charged to Federal programs. In addition, IW
could not readily provide evidence that it had assessed whether or not its vendors were suspended,
debarred, or otherwise excluded. As a result, the potential for payments to suspended, debarred, or
otherwise excluded vendors and individuals exists.
Recommendation: IW should revise its procurement policy so that it conforms to the Uniform
Guidance. Furthermore, IW should maintain documentation in its files to provide evidence to support
that it followed the procurement policy. In addition, IW should establish internal controls to ensure
documentation is maintained to evidence that it performed the required suspension and debarment
searches on the SAM website.