Finding Text
Finding 2022-001: Suspension/Disbarment Searches Assistance listing number and name: 19.040 ? Public Diplomacy Programs 19.900 - AEECA/ESF PD Programs Year: 2022 Federal agency: U.S. Department of State Criteria: Per 2 CFR section 200.214, non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180, which 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. 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, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition and context: During our audit, we noted that IWPR did not perform timely, the search whether vendors were suspended or debarred, prior to payments. The searches were ultimately performed in 2023 but not during the procurement process in 2022 as required by the internal policy that vetting should be carried out prior to the procurement. This was rectified by performing ?post dated? vetting which confirmed IWPR did not support suspended or debarred parties. Cause: IWRP was aware of the requirement but due to turnover in the staff, this was not performed in timely manner. Effect: Vendors used could have been used for services performed as part of the federal award whilst suspended or disbarred. No vendors used were suspended or disbarred and thus there are no questioned costs. Repeat finding: No. Questioned costs: None noted. Recommendation: We recommend that management reviews periodically, if there is staff turnover, that the searches as part of its initial procurement processes and controls and retain documentation for each vendor. Views of responsible officials and planned corrective actions: Management acknowledges the finding and has implemented correction actions. See corrective action plan.