Finding 480944 (2023-001)

Type: Federal Award - Significant Deficiency in Internal Control over Compliance – Procurement and Suspension & Debarment AL Number: 11.469 – Congressionally Identified Awards and Projects Criteria/Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. According to 2 CFR section 180, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Condition/Context: In 1 of 1 procurement sample tested the vendor was not verified by the Organization for suspension or debarment. A retroactive verification was run showing the vendor was not suspended or debarred. Cause: The Organization’s policy states that they will ensure that a contractor is not suspended nor debarred by a federal agency. However, the policy was not followed. Effect: A suspended or debarred vendor may be used. Questioned Costs: None Recommendation: The Organization should follow the internal policy established, verifying a vendor is not suspended or debarred before entering covered transactions. This could be done by documenting the use of Sam.gov to search for the entity’s name against the exclusions listing, by collecting a certification from the entity, or by adding a clause or a condition to the contract with the entity. A checklist for procurement or a procurement summary document might also assist in ensuring the Organization is following the established policy. Management’s Response: Management concurs with the finding and has developed a corrective action plan. We understand a deficiency is identified in the internal control over compliance. We place the utmost importance on the summary of auditors’ results and will work to increase the strength of our internal controls over compliance.