Finding 505436 (2024-005)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2024-11-12

AI Summary

  • Core Issue: UAS's procedures for checking if vendors are suspended or debarred are incomplete, only applying to certain contracts and purchases.
  • Impacted Requirements: Compliance with the Uniform Guidance and 2 CFR section 180.300 is at risk, as not all covered transactions are reviewed for vendor status.
  • Recommended Follow-Up: Update policies to include checks for all vendors, not just those under specific contracts, and implement regular monitoring for compliance.

Finding Text

2024-005 Suspension and Debarment Programs: 16.820 Post Conviction DNA Testing, 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: The Uniform Guidance and 2 CFR section 180.300 require that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded. Condition: UAS’s suspension and debarment procedures only apply to subrecipient contracts and goods and services obtained via purchase order which allows for covered transactions to occur without sufficient review of entity status if not transacted in one of these two ways. Cause: UAS’s policy does not define when suspension and debarment procedures should be performed. Effect: UAS engaged in covered transactions without reviewing the entity’s suspended or debarred status. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: While UAS’s Subrecipient Commitment form and CSU General Provisions for Service Acquisitions referred to in the standard Purchase Order form contain either a self-declaration or suspension and debarment clause, the Contractor Service Agreement does not include this language. Two covered transactions tested with a Contractor Service Agreement did not appear to be reviewed for suspension and debarment prior to entering the transaction, although did appear to adhere to other applicable procurement policies. Auditors tested a selection of expenditures to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing. Repeat Finding: No. Recommendation: Enhance the current policy to include checking suspension and debarment status for vendors without a purchase order meeting the covered transaction definition, either through checking SAM Exclusions, obtaining a self-declaration/certification, or by adding a clause or condition to the transaction. Expand the policy to include ongoing monitoring of active vendors by checking for suspension and debarment status on a regular basis, but at least annually. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 505419 2024-003
    Material Weakness
  • 505420 2024-003
    Material Weakness
  • 505421 2024-003
    Material Weakness
  • 505422 2024-003
    Material Weakness
  • 505423 2024-004
    Significant Deficiency
  • 505424 2024-004
    Significant Deficiency
  • 505425 2024-004
    Significant Deficiency
  • 505426 2024-004
    Significant Deficiency
  • 505427 2024-004
    Significant Deficiency
  • 505428 2024-004
    Significant Deficiency
  • 505429 2024-004
    Significant Deficiency
  • 505430 2024-004
    Significant Deficiency
  • 505431 2024-004
    Significant Deficiency
  • 505432 2024-005
    Significant Deficiency
  • 505433 2024-005
    Significant Deficiency
  • 505434 2024-005
    Significant Deficiency
  • 505435 2024-005
    Significant Deficiency
  • 505437 2024-006
    Significant Deficiency
  • 505438 2024-006
    Significant Deficiency
  • 505439 2024-006
    Significant Deficiency
  • 505440 2024-006
    Significant Deficiency
  • 1081861 2024-003
    Material Weakness
  • 1081862 2024-003
    Material Weakness
  • 1081863 2024-003
    Material Weakness
  • 1081864 2024-003
    Material Weakness
  • 1081865 2024-004
    Significant Deficiency
  • 1081866 2024-004
    Significant Deficiency
  • 1081867 2024-004
    Significant Deficiency
  • 1081868 2024-004
    Significant Deficiency
  • 1081869 2024-004
    Significant Deficiency
  • 1081870 2024-004
    Significant Deficiency
  • 1081871 2024-004
    Significant Deficiency
  • 1081872 2024-004
    Significant Deficiency
  • 1081873 2024-004
    Significant Deficiency
  • 1081874 2024-005
    Significant Deficiency
  • 1081875 2024-005
    Significant Deficiency
  • 1081876 2024-005
    Significant Deficiency
  • 1081877 2024-005
    Significant Deficiency
  • 1081878 2024-005
    Significant Deficiency
  • 1081879 2024-006
    Significant Deficiency
  • 1081880 2024-006
    Significant Deficiency
  • 1081881 2024-006
    Significant Deficiency
  • 1081882 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.031 Higher Education Institutional Aid $475,908
84.047 Trio Upward Bound $353,804
16.820 Postconviction Testing of Dna Evidence $337,028
93.658 Foster Care Title IV-E $334,886
84.336 Teacher Quality Partnership Grants $236,942
93.173 Research Related to Deafness and Communication Disorders $202,764
84.335 Child Care Access Means Parents in School $178,356
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $163,388
47.074 Biological Sciences $158,011
43.012 Space Technology $144,867
47.050 Geosciences $135,442
81.089 Fossil Energy Research and Development $129,456
93.865 Child Health and Human Development Extramural Research $119,953
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $106,252
93.359 Nurse Education, Practice, Quality and Retention Grants $105,849
21.027 Coronavirus State and Local Fiscal Recovery Funds $96,712
43.008 Office of Stem Engagement (ostem) $91,661
94.006 Americorps State and National 94.006 $88,631
84.235 Rehabilitation Services Demonstration and Training Programs $88,300
16.540 Juvenile Justice and Delinquency Prevention $80,375
81.U02 Battery Workforce Challenge $74,670
47.049 Mathematical and Physical Sciences $74,566
93.596 Child Care and Development Block Grant $68,172
93.859 Biomedical Research and Research Training $68,023
12.300 Basic and Applied Scientific Research $64,697
84.021 Overseas Programs - Group Projects Abroad $64,660
20.701 University Transportation Centers Program $61,087
93.867 Vision Research $54,155
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $52,269
10.223 Hispanic Serving Institutions Education Grants $51,193
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $43,665
93.310 Trans-Nih Research Support $42,434
10.558 Child and Adult Care Food Program $42,380
93.575 Child Care and Development Block Grant $37,334
93.247 Advanced Education Nursing Grant Program $36,357
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $36,042
93.394 Cancer Detection and Diagnosis Research $33,819
47.076 Stem Education (formerly Education and Human Resources) $30,329
47.070 Computer and Information Science and Engineering $29,407
10.310 Agriculture and Food Research Initiative (afri) $28,966
93.279 Drug Abuse and Addiction Research Programs $28,516
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $25,993
47.075 Social, Behavioral, and Economic Sciences $25,838
47.041 Engineering $16,242
84.015 National Resource Centers Program for Foreign Language and Area Studies Or Foreign Language and International Studies Program and Foreign Language and Area Studies Fellowship Program $15,183
84.120 Minority Science and Engineering Improvement $10,503
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $9,526
10.707 Research Joint Venture and Cost Reimbursable Agreements $7,241
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $7,237
81.049 Office of Science Financial Assistance Program $6,019
15.530 Water Conservation Field Services (wcfs) $1,666
43.001 Science $1,529
12.U01 Mentor Protégé Program $1,020
43.007 Space Operations $1,000
16.812 Second Chance Act Reentry Initiative $952