Finding 523962 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2025-02-19
Audit: 343141
Organization: Micronesia Conservation Trust (FM)

AI Summary

  • Core Issue: The Trust failed to verify that a vendor was not debarred or suspended before entering into a contract.
  • Impacted Requirements: This violates 2 CFR 200.214 and 2 CFR 180.300 regarding vendor eligibility for Federal assistance.
  • Recommended Follow-Up: Implement and document procedures to ensure compliance with debarment checks for all vendors in procurement files.

Finding Text

Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 523960 2022-001
    Significant Deficiency
  • 523961 2022-001
    Significant Deficiency
  • 523963 2022-002
    Material Weakness
  • 523964 2022-002
    Material Weakness
  • 523965 2022-002
    Material Weakness
  • 1100402 2022-001
    Significant Deficiency
  • 1100403 2022-001
    Significant Deficiency
  • 1100404 2022-001
    Significant Deficiency
  • 1100405 2022-002
    Material Weakness
  • 1100406 2022-002
    Material Weakness
  • 1100407 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
11.482 Coral Reef Conservation Program $304,668
98.001 Usaid Foreign Assistance for Programs Overseas $26,882
15.875 Economic, Social, and Political Development of the Territories $5,563
10.664 Cooperative Forestry Assistance $3,505