Finding 499013 (2023-002)

Condition: The Foundation’s controls over compliance were not sufficient to prevent the Foundation from entering into contracts without obtaining certification from the contractor that it was not debarred or suspended. Criteria: In accordance with 2 CFR Part 180, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. To comply with this requirement, the Foundation has developed written policies to require that all contracts include a clause certifying that the contractor is not debarred or suspended from participating in contracts involving federal assistance. Cause: The Foundation did not follow its written procedures for two covered transactions. Effect: The Foundation could have unknowingly entered into contracts with debarred or suspended parties. Recommendation: Management should ensure its written policies and procedures regarding debarred and suspended parties are followed before executing contracts to be reimbursed by federal assistance. Views of Responsible Officials and Planned Corrective Actions: The Foundation agrees with the finding and procedures have been implemented.