Finding Text
Finding 2022-002 U.S. Department of Education Native Hawaiian Education Assistance Listing No. 84.362A Criteria ? Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at Sections 200.318 through 200.326 of the Uniform Guidance. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in the Uniform Guidance. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition ? During the audit for the year ended December 31, 2022, the Organization did not have written policies and procedures that met the procurement standards set out at Sections 200.318 through 200.326. The Organization did not verify that vendors and contractors were not suspended or debarred. Cause ? The Organization did not have written policies and procedures that met the procurement standards set out at Sections 200.318 through 200.326. The Organization did not verify that its vendors and contractors were not suspended or debarred. Effect or Potential Effect ? The Organization may not be in compliance with the procurement requirements of the Uniform Guidance. The Organization may be engaging in transactions with entities that are suspended or debarred. Questioned Costs ? Unknown. The Organization had $573,039 in nonpayroll costs included in its federal expenditures during the year ended December 31, 2022. Recommendation ? Develop and implement policies and procedures that meet the procurement requirements of the Uniform Guidance. Implement policies and procedures that include the verification that new vendors and contractors are not suspended or debarred and existing vendors and contractors are periodically checked to verify that they have not been suspended or debarred. Responsible Official?s Response and Corrective Action Planned ? Refer to the Corrective Action Plan.