Finding 497038 (2023-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-17

AI Summary

  • Core Issue: The Center failed to check and document whether vendors, contractors, or consultants are suspended or debarred, risking improper use of federal funds.
  • Impacted Requirements: This violates 2 CFR §200.303 and 2 CFR part 180, which mandate effective internal controls and compliance with debarment regulations.
  • Recommended Follow-Up: Implement internal controls for vendor screening and establish a policy for annual checks on current vendors to ensure compliance.

Finding Text

Finding 2023-004: Suspension and Debarment Federal Programs: All programs Criteria: As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Center) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-Federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. Condition: During our audit, we noted several cases in which the Center did not perform, or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: During 2023, the Center's finance department turned over significantly, resulting in oversight of the compliance requirement. Effect or Potential Effect: The Center is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. If a non-Federal entity knowingly does business with an excluded person, the agency responsible for the Center's funding may disallow costs, annul or terminate the transaction, issue a stop work order, debar or suspend the non-Federal entity, or take other remedies as appropriate. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 497034 2023-003
    Significant Deficiency
  • 497035 2023-004
    Significant Deficiency
  • 497036 2023-002
    Significant Deficiency Repeat
  • 497037 2023-003
    Significant Deficiency
  • 497039 2023-005
    Significant Deficiency
  • 497040 2023-006
    Significant Deficiency
  • 497041 2023-003
    Significant Deficiency
  • 497042 2023-004
    Significant Deficiency
  • 497043 2023-003
    Significant Deficiency
  • 497044 2023-004
    Significant Deficiency
  • 497045 2023-003
    Significant Deficiency
  • 497046 2023-004
    Significant Deficiency
  • 497047 2023-003
    Significant Deficiency
  • 497048 2023-004
    Significant Deficiency
  • 497049 2023-003
    Significant Deficiency
  • 497050 2023-004
    Significant Deficiency
  • 1073476 2023-003
    Significant Deficiency
  • 1073477 2023-004
    Significant Deficiency
  • 1073478 2023-002
    Significant Deficiency Repeat
  • 1073479 2023-003
    Significant Deficiency
  • 1073480 2023-004
    Significant Deficiency
  • 1073481 2023-005
    Significant Deficiency
  • 1073482 2023-006
    Significant Deficiency
  • 1073483 2023-003
    Significant Deficiency
  • 1073484 2023-004
    Significant Deficiency
  • 1073485 2023-003
    Significant Deficiency
  • 1073486 2023-004
    Significant Deficiency
  • 1073487 2023-003
    Significant Deficiency
  • 1073488 2023-004
    Significant Deficiency
  • 1073489 2023-003
    Significant Deficiency
  • 1073490 2023-004
    Significant Deficiency
  • 1073491 2023-003
    Significant Deficiency
  • 1073492 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.124 East Asia and Pacific Grants Program $515,454
19.345 International Programs to Support Democracy, Human Rights and Labor $225,324
19.901 Export Control and Related Border Security $140,949
19.017 Environmental and Scientific Partnerships and Programs $137,024
98.001 Usaid Foreign Assistance for Programs Overseas $76,096
19.026 Global Peace Operations Initiative $47,952
19.040 Public Diplomacy Programs $10,151