Finding Text
Finding Number: 2022-001 Information on the Federal Program: Federal Agency: U.S. Department of Transportation Program Name: Formula Grants for Rural Areas and Tribal Transit Programs AL: 20.509; Federal Award Identification Number: 04-96-96-964010-2916-072-500575 Federal Award Year: Year Ended June 30, 2022 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Association did not review the SAM for vendors meeting the covered transaction threshold. Context: Based on our testing, we noted that none of the 4 vendors selected in our testing that were charged to the grant were included in the SAM listing. Although we did note the Association has a process to review employees upon hire and on a monthly basis to the SAM.gov listing, this review does not occur for vendors. Questioned Costs: None. Cause and Effect: The Association was unaware of the requirement to verify vendors against the SAM. Since this process was not performed on vendors, there was a risk that vendors who may be included on the SAM were included in this federal program. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend the Association implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Association should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation.