Finding Text
Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.