Finding 496862 (2023-001)

Finding 2023-001 Suspension and Debarment Federal Program: ALN 98.U01 Criteria: Recipients of U.S. Government funds must adhere to specific requirements on screening all potential vendors, suppliers and sub-contractors/grantees to ensure the organization is not conducting business with excluded parties (as defined by the U.S. Government); the screening must be documented in writing. Condition: During the first three quarters of the year under audit, the Foundation did not perform and/or adequately document the screening process for payments made with Federal funds. Our audit procedures consisted of substantive testwork over a sample of expenditures paid during the year that were selected based on a representative sample of the population. Context: Payments were made during the first three quarters of the year by the Foundation without performing and/or adequately documenting the screening process. Effect: Failure to screen potential vendors, suppliers, employees, fellows or other non-contracted Federal transactions against the suspended and debarred list increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded parties by the U.S. Government. Cause: The Foundation did not have adequate policies and procedures in place during the first three quarters of the year to perform and document the screening process. Questioned Costs: Undetermined. Repeat Finding: Finding 2022-001. Recommendation: This was first brought to management's attention during the fiscal year 2022 audit, which occurred during fiscal year 2023. At that time, we recommended management of the Foundation strengthen the policy surrounding the screening process for all contracted and noncontracted transactions including, but not limited to, with vendors, suppliers, employees, and fellows. Furthermore, we recommended that management communicate these policies and procedures to employees of the organization, and it should stress the importance of documenting compliance with the “Suspension and Debarment” provisions. Finally, we recommended the screening of potential vendors and suppliers should be completed (and documented) prior to entering into the transactions or making payments. We noted management took steps by the end of fiscal year 2023 to address these recommendations and remediate the finding.