Finding Text
2022 ? 001 Procurement ? Suspension and Debarment Federal Agency: U.S. Department of State Federal Program Title: Improve Relations Between Stakeholders in the United States and Other Countries/Promoting American Leadership, Democratic Values, and Economic Prosperity Federal Assistance Listing Number: 19.040/19.700 Award Period: September 30, 2019 ? December 31, 2024/September 27, 2019 ? March 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Atlantic Council of the United States, Inc. should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted The Atlantic Council of the United States, Inc. did not have documentation to support that internal controls were performed to ensure vendors were not suspended or debarred prior to entering into the contract. Questioned costs: None Context: During our testing, it was noted that for 5 of 5 items tested that The Atlantic Council of the United States, Inc. did not have documentation to support that it had reviewed vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. We verified that the selected vendor was not suspended or debarred. Cause: The Atlantic Council of the United States, Inc. was unable to locate documentation to support the performance of procedures to ensure vendors were not suspended or debarred. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend The Atlantic Council of the United States, Inc. design controls to ensure an adequate review process is in place to review potential vendors to determine they are not suspended or debarred and to ensure documentation to support this is maintained. Views of responsible officials: Management accepts the audit finding, noting that internal controls were in place but not able to be verified. The Council staff followed procurement procedures, but documentation did not sufficiently show timeliness. As of the audit finalization, relevant processes have been modified to ensure that the issue does not recur.