Finding Text
Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a nonfederal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction greater than $25,000 is not debarred, suspended, or otherwise excluded. Condition: The College did not have a policy in place to verify that a vendor had not been suspended or debarred, at the time the College entered into certain transactions greater than $25,000 with vendors. This policy was updated late in the year ended June 30, 2022, and the vendors were reviewed at that time. Questioned costs: None Context: This condition occurred for 5 of 5 vendors selected for testing. Cause: The general Terms & Conditions attached to College Purchase Orders were designed to protect the College when entering into agreements with vendors. Unfortunately, these Terms & Conditions were not updated to include the Uniform Guidance criteria pertaining to transactions with debarred, suspended or otherwise excluded vendors until late in the year ended June 30, 2022. Effect: The College could enter a covered transaction with a vendor who is suspended or debarred and not be in compliance with Uniform Guidance requirements. Repeat Finding: Yes Recommendation: We recommend the College continue to follow its policy which dictates how the College will ensure suspension and debarment procedures are followed for any aggregate disbursements with vendors greater than $25,000. This process should occur prior to entering into the transaction. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.