Finding Text
Procurement – Suspension and Debarment
Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323.
Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs.
Statement of Condition: During our testing for procurement compliance, it was determined that the New York State Sheriffs’ Association, Inc. did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs.
Questioned Cost: None
Statement of Cause: Management was not aware of the requirement to review an entity’s status.
Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Association could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs.
Repeat Finding: Yes
Perspective Information: There was one vendor in excess of the $25,000 threshold which was reviewed to determine eligibility for participation noting they are not debarred, suspended, or otherwise excluded from participation in federal award programs.
Recommendation: We recommend management review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs.
Views of the Responsible Officials and Planned Corrective Actions: Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system.
Based on the timeline of the 2022 audit, many of the corrective actions were made in late Oct/November 2023.