Finding Text
Criteria
The OMB Circular 133, establishes when a non-Federal entity enters a covered
transaction with an entity at a lower tier, the non-Federal entity must verity that the
entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not
suspended, or debarred or otherwise excluded from participating in the transaction.
This verification may be accomplished by (1) checking the Excluded Parties List
System (EPLS) maintained by the General Services Administration (GSA) and
available at http://www.sam.gov/portal/public/SAM/.
We found it is not recorded in http://www.sam.gov/portal/public/SAM/. We didn’t
find DUNS number and is possible is not an active company and doesn’t know if
that company is suspended or debarred or otherwise excluded from participating
for Head Start and Head Start Disaster Recovery from Hurricanes Harvey, Irma and
María programs.
Condition
The Municipality’s disbursement test, we found (2) two disbursements without
System Award Management number or not active with funds payments more than
$25,000.
Questioned costs
Not determined
Cause
Program officials did not verify if they are Excluded Parties List System (EPLS)
maintained by the General Services Administration (GSA) that the contracted entity
was suspended or debarred.
Effect
There is a risk that the contracted entity may have been debarred and might not
comply with the contract requirements, the program may recover funds.
Recommendation
We recommend that the potential entity to be contracted is verified on the internet
http://www.sam.gov/portal/public/SAM/ to assure there is no exclusions.
Management Response
The Municipality does not accept this finding. Based on the performance standards and the
uniform guidance it is not a requirement that all potential contractors be registered in
SAM.gov; however, both the Head Start Performance Standards and the Uniform Guidance
state that the recipient may follow their own policies and procedures when it comes to
procurement. See 1303.55/75.327
The Municipality of Barceloneta, as a measure to ensure the best interests of its funds,
validates the reputation of its suppliers both in sam.gov and, failing that, with the General
Services Administration.