Finding 513768 (2024-001)

001 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Identification of the Federal Program: United States Agency for International Development (USAID) Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award Information: Pass-through Entity Pass-through Award Number Award Period IPE Global Limited IPE-DOM-2022 January 25, 2022 through August 31, 2023 Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of ten procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management had most recently performed a suspension and debarment check on this vendor in 2021 for a previously covered transaction. Management has also performed a new suspension and debarment check on this vendor when this condition was identified noting no suspension and debarment issues. Cause: ChildFund policies and procedures did not require suspension and debarment checks be performed prior to entering a covered transaction if a check had been done within the previous three years. Effect: Failure to timely verify that a vendor is not suspended or debarred prior to each covered transaction with that vendor could result in unintentionally entering into a contract with an vendor that is suspended or barred from performing work for the Federal government. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of ChildFund’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management perform the suspension and debarment checks before each covered transaction is executed. Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.