Finding 43788 (2022-001)

Finding 2022-001: Procurement, Suspension and Debarment Federal Program COVID-19 Education Stabilization Fund (ALN: 84.425) Federal Agency U.S. Department of Education Federal Award Year July 1, 2021 through June 30, 2022Criteria or Requirement Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition Found, Including Perspective In our testing over vendor suspension and debarment, we noted two vendors related to which the College did not maintain documentation over its verification that the vendors with whom the College procured goods and services from were not suspended or debarred. Neither vendors were suspended nor debarred. Possible Cause and Effect Management?s control over its review of vendor suspension and debarment was not operating effectively to ensure compliance with certain procurement requirements for the year ended June 30, 2022 for vendors where the purchases were made via a purchasing card. Questioned Costs None identified. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year Yes. Recommendation We recommend management enhance its process level controls over procurement requirements for HEERF to ensure vendors are not suspended nor debarred. View of Responsible Officials All vendors paid directly by Davidson College were verified against the suspension and debarment website prior to assigning HEERF funds to the invoices. However, the College failed to perform the same verification for vendors paid using the College?s corporate purchasing cards (Pcards). Those vendors were verified after the fact and were not found on the suspension and debarment website.