Finding Text
Control Deficiency ? Suspension and Debarment (Repeated and Modified)Condition: During our testwork over Suspension and Debarment, we noted 1 of 6 covered transactions tested for which SFI did not confirm the vendor was not suspended or debarred prior to entering into the transaction. Criteria or specific requirement: According to ?200.303 Internal controls of 2 CFR Part 200, the non- Federal 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. 2 CFR Part 180.300 outlines the requirements to verify that covered individuals are not excluded or disqualified. Questioned costs: None Context: The prior year corrective action plan had a planned completion date of December 31, 2022, and this covered transaction originated in 2021. Management performed a check at the beginning of 2023, and noted the vendor was not suspended or debarred, but could not substantiate this check retroactively. Cause: Transitions in personnel/management oversight. Effect: Without appropriate controls in place the organization may entered into an agreement with a covered person or entity that is not eligible. Repeat Finding: Yes Recommendation: We recommend management follow internal processes to ensure that checks are performed to conform with 180.300 of the CFR prior to entering into covered transactions. Views of responsible officials: Management agrees with the finding and has strengthened internal controls to meet the requirement. Management has discussed the requirements with all necessary parties and has instituted the new controls for setting up sub-contracts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Actions planned in response to finding: Management has implemented additional controls to be performed by the Sponsored Research department and VP of Administration office to better monitor and track sub-contractor debarment status prior to their being brought onboard for work with SFI. Additionally, a list of all vendors that needed Suspension and Debarment from the previous year will be reviewed in January of the following year as SFI utilizes vendors over multiple years due to limited availability of vendors to provide necessary services. Responsible party: Suzette A. Fronk, Chief Financial Officer Planned completion date for corrective action plan: September 1, 2023 Plan to monitor completion of corrective action plan: In conjunction with the VP of Administration, Sponsored Research Office, and the Chief Financial Officer, SFI?s Finance Committee will monitor the completion of the corrective action plan.