Finding Text
Suspension and Debarment
Significant Deficiency in Internal Control Over Compliance
Criteria – The Uniform Guidance requires that 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 is not
suspended or debarred or otherwise excluded from participating in the transaction (§200.214).
Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be
funded with federal funds.
Condition – Civic Arts does not have a procedure designed to identify vendors that are suspended
or debarred.
Cause – Civic Arts was not aware of the requirement to verify vendors are not suspended or
debarred.
Effect – A vendor who is suspended or debarred could be paid with federal funds inappropriately.
Recommendations – Civic Arts should implement a process to compare all vendors meeting the
covered transaction threshold to the System for Award Management (SAM) on a regular basis and
when a new vendor is entered into the accounting system. This procedure should be documented
when it is performed.