Finding Text
Finding 2022-007: Suspension and Debarment
Criteria: Under 2 CFR §200.213, Non-Federal entities are subject to the non-procurement debarment
and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These
regulations restrict awards, subawards, and contracts with certain parties that are debarred,
suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities. The non-Federal entity must verify that the person with whom you intend to do business is
not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that
person; or (c) Adding a clause or condition to the covered transaction with that person.
Condition: During our testing over Suspension and Debarment, we determined that SAMU did not
perform screenings on potential or current vendors, suppliers, contractors or employees that were paid
with Federal funds. Cause: SAMU does not have a formal internal policy with respect to screening vendors, suppliers,
contractors and employees in order to adhere to compliance over suspension and debarment.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and
employees increases the potential that Federal funds be inadvertently provided to parties deemed to
be suspended or disbarred by the United States Government.
Questioned Costs: None.
Context: We noted that vendors, suppliers, contractors and employees selected for testing did not
have a formally documented Suspension and Debarment check conducted prior to engagement.
Identification as a Repeat Finding, if Applicable: Not applicable.
Recommendation: We recommend that management develop and implement a formal policy on
suspension and debarment. This policy should include a threshold for when vendors, suppliers,
contractors and employees should be screened. All screenings should be conducted prior to signing a
contract or issuing payment. We recommend that SAMU notify all employees of this policy and ensure
that it is enforced during the upcoming fiscal year.