Finding Text
Condition: The Organization did not verify that contractors used were not suspended, debarred or otherwise excluded prior to entering into a contract with them. Criteria: OMB Uniform Guidance ?200.180 provides that non-federal entities cannot enter into transactions with parties that are suspended or debarred from doing business with the federal government. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2022 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. As noted in finding 2022-001, the Organization's purchasing policies did not comply with the Uniform Guidance. The Organization was not aware that contractors should be verified prior to entering into a contract under the Uniform Guidance. Effect: It is possible that the Organization enters into a contract with a contractor that has been suspended, debarred or otherwise excluded. Recommendation: The Organization's written procurement policies should include a procedure to verify that contractors are not suspended, debarred or otherwise excluded prior to entering into a contract, and the Organization should perform and document these procedures performed. Views of Responsible Officials and Planned Corrective Actions: Two of the contracts noted were originally entered into prior to the increase in the Organization's federal funding and being subject to the Uniform Guidance. No contracts were entered into with vendors that were suspended, debarred, or otherwise excluded. Written procurement and conflict of interest policies, in accordance with the Uniform Guidance, will be established and implemented during the year ended June 30, 2023.