Finding 480112 (2023-006)

Finding Number: 2023-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 35 vendors and 15 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-006, 2021-006, 2020-007 and 2019-008 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.