Finding Text
Federal Assistance Number - Research and Development Cluster, Multiple Federal Grantors, Multiple Award Periods Criteria or Specific Requirement - Procurement In accordance with 2 CFR Section 180.220, 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 - Suspension and debarment checks were not completed for all vendors that received Federal funds. Questioned Costs - None noted. Context - One of two vendors subject to procurement requirements in 2022 was selected for testing. The Institute purchased approximately $213,900 in goods from this vendor in 2022. During our testing it was noted that the Institute did not check the vendors suspension and debarment status prior to purchase. The Institute completed the suspension and debarment check subsequent to purchase and verified that the vendor was not suspended or disbarred. The sample was not intended to be, and was not, a statistically valid sample. Effect - Federal funds could be paid to entities that are suspended or debarred. Cause - The Institute's controls to ensure suspension and debarment checks were performed on vendors receiving Federal funds did not operate effectively. Identification as a Repeat Finding, if applicable - Not a repeat finding. Recommendation - Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors prior to making purchases with Federal funds. View of Responsible Official and Planned Corrective Actions ? Management agrees with the stated finding and has implemented a corrective action plan.