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2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.