Finding Text
U.S. Department of Agriculture Distance Learning and Telemedicine Grant Program Assistance Listing Number: 10.855 Grant Number: TX0787-A67 Grant Period: Year Ended September 30, 2022 Criteria: Under 2 CFR Section 200.303(a) and 2 CFR Section 180, Subpart C, non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statutes, regulations, and the terms and conditions of the federal award. Condition: The District does not have documented controls to prevent purchases using federal funds from suspended or debarred vendors. Cause: While the District has policies and procedures for procurement, these do not encompass verifying that the potential vendor is suspended or debarred from receiving federal funding as required under 2 CFR Section 180, Subpart C. Effect: Purchases from suspended or debarred vendors would result in disallowed costs, and the federal funds would be required to be returned to the funding agency. Questioned Costs: None Perspective: Because a formal policy is not established, the one vendor meeting the threshold was not subjected to suspension and debarment testing by the District. Recommendation: The District should establish procedures to ensure that controls related to suspension and debarment are continuously implemented and that all written records are maintained to support that the compliance requirement is met. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding, and procurement policies and procedures will be updated to include a control to verify that a vendor is not suspended or debarred.