2023-002 Material Weakness in Internal Controls – Procurement, Suspension and Debarment
Funding Agency: Department of Education
Program: Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Direct Spending for Elementary and Secondary Education Community Projects
Assistance Listing Number: 84.215K
Condition:
None of the five samples selected for testing had appropriate suspension and debarment checks prior to entering into the subawards.
Criteria or Specific Requirement:
Criteria or specific requirement: 2 CFR 200.318(i) states that "non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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.
Effect:
The Organization was unaware of the requirement to perform suspension and debarment checks on subrecipients. Without proper controls the Organization could enter award subrecipients with entities that are suspended or debarred.
Cause:
The Organization was unaware of the requirement to perform suspension and debarment checks on subrecipients. Without proper controls the Organization could enter award subrecipients with entities that are suspended or debarred.
Recommendation:
The Organization should implement policies and procedures for performing suspension and debarment checks for all covered transactions, including subrecipients.
Questioned Costs:
None
View of Responsible Official and Corrective Action
Management accepts the finding and is taking the following corrective action to prevent recurrence:
• Procurement training planned throughout the agency to ensure that personnel authorized to initiate procurement transactions are aware of organizational policies and have the guidance necessary to comply with procurement rules.
Anticipated Completion Date: Corrective action is currently being implemented.