Finding Text
Information on the Federal Program: Assistance Listing Number 47.050—Geosciences, National Science Foundation. Award Number: 224242, 2303562, 2243827, 2246223, 2246225. Compliance Requirements: Procurement Suspension and Debarment Type of Finding: Material Noncompliance and Significant Deficiency.
Criteria: Under 2 CFR § 200.214 - Suspension and Debarment, recipients and subrecipients of federal funding must adhere to the nonprocurement debarment and suspension regulations that implement Executive Orders 12549 and 12689, as well as 2 CFR Part 180. These regulations prohibit making federal awards, subawards, and contracts with parties that are debarred, suspended, or otherwise excluded from participation in federal programs. Entities must have a documented policy to ensure compliance with these requirements
Condition: For the year ended March 31, 2024, Future Earth did not have a written policy for suspension and debarment. Additionally, no control was in place to ensure compliance with these regulations.
Cause: This was the second year Future Earth was awarded Federal funding and was unaware of this requirement.
Effect: Without a documented policy for suspension and debarment, the Future Earth risks inadvertently engaging in contracts with suspended or debarred vendors. This can lead to noncompliance with federal regulations and potential financial penalties
Questioned Costs: None.
Context: In our testing of two procurement transactions totaling $116,404 which were subject to suspension and debarment regulation, out of total transactions subject to procurement of $220,192, it was noted that management did not verify the vendors were not suspended/debarred. Upon further research, the auditor was able to verify that neither vendor was suspended/debarred.
Recommendation: We recommend that Future Earth develop a written policy to check all vendors for suspension and debarment on SAM.gov prior to awarding contracts.
Views of Responsible Official: Management agrees with this finding. Please see corrective action plan at the end of this report.