Finding Text
Criteria or Specific Requirement: 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: We sampled five covered transactions that lacked documentation supporting that the vendor was not suspended or debarred. Questioned Costs: None Context: Of the five covered transactions tested, all lacked documentation supporting that the College verified the vendor was not suspended or debarred prior to entering into the covered transactions. Cause: Management did not retain evidence demonstrating they verified the vendors were not suspended or debarred prior to entering into the covered transaction. Similar instances of noncompliance were reported in the prior year audit, but was not brought to the College?s attention until after the fiscal year. Effect: By not retaining evidence that Management verified vendors were not suspended or debarred, management may erroneously enter into a covered transaction with vendors that were suspended or debarred. Repeat Finding: Yes, see 2021-003 Recommendation: We recommend Management adopt a policy to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the GSA website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. Views of responsible officials: Management agrees with finding.