Finding Text
Finding 2023-004: Procurement, Suspension, and Debarment (Significant Deficiency)
Information on the Federal Programs: Both Major Programs
Criteria or Specific Requirement: 2 CFR Section 200.318 requires that the non-Federal entity
must have and use documented procurement procedures, consistent with State, local, and tribal
laws and regulations and the standards of this section, for the acquisition of property or services
required under a Federal award or subaward. The non-Federal entity's documented procurement
procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. In
addition, 2 CFR Section 200.214 requires that, for covered transactions, a non-Federal entity must
verify that entities are not suspended, debarred or otherwise excluded. This verification may be
accomplished by checking the System for Award Management (SAM) website maintained by the
General Services Administration.
Condition: FCE did not have a documented procurement policy until January 2024. In addition, for
all disbursements tested, FCE did not verify, prior to payment, that the vendors were not suspended,
debarred or otherwise excluded. However, FCE provided documentation of the verification that
occurred after the payments had been made and no exclusion issues were noted with the vendors.
Cause: Prior to the implementation of a formal procurement policy in January 2024, FCE did not
require that evidence of SAM checks be maintained in its vendor files. However, FCE performed a
search after the payments had been made. In this way, FCE was able to verify that the vendors or
individuals in our sample were not suspended, debarred or otherwise excluded.Effect or Potential Effect: FCE was not in compliance with the procurement policy and
documentation requirements of the Uniform Guidance until January 2024.
Questioned Costs: None.
Repeat Finding: See Findings 2022-002 and 2022-003.
Recommendation: FCE established internal controls in January 2024 to ensure proper
documentation is maintained as evidence to support that it performed the required suspension and
debarment searches on the SAM website.