Finding Text
2022-001 ? Suspension and Debarment - Significant Deficiency Federal Program Information: Funding Agency: Department of Agriculture Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass Through Award Number: 21000 Pass Through Entity: State of NM PED Award Year: 2022 Condition: Both samples selected for testing vendor eligibility on sam.gov, we noted the District did not have documentation to support that a review was taken place on vendor eligibility. Per 2 CFR section 200.303 ? Internal Controls ? The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: No questioned costs identified. Effect: If a vendor has been disbarred from receiving Federal funds, the Organization may be liable to pay for the amount and not be reimbursed. Cause: The District did not follow proper Federal policies related to verification of vendors from the excluded parties list system. Auditors? Recommendation: The auditor recommends that the District verify that all vendors are not listed on the excluded parties list system by performing a search on sam.gov and maintaining the results of such search in the vendor?s file. Views of Responsible Officials of Auditee: During the 2021-22 audit, the documentation to support vendor eligibility was not in the vendor?s paperwork for verification. The current process for vendor verification requires a New Vendor Form, a current W-9 Form, Sam.Gov verification of the vendor?s registration status, and an IRS TIN Match, a requirement implemented in FY 2021-22. All of the information obtained is then filed in a vendor file. To avoid any future deficiency, the Purchasing Department will submit a Sam.Gov verification of all vendors that will be utilizing federal funds.