Finding 525789 (2024-001)

Criteria: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify 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. “Covered transactions” include those procurement contracts for goods and services awarded under non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. The Barrington School Department has a policy in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. Condition: During our test of controls over compliance with suspension and debarment requirements, we selected four transactions subject to suspension and debarment requirements that had no documentation on file to support that the School Department verified the entity was not suspended, debarred, or otherwise excluded. Cause: The School Department did not follow established suspension and debarment policies and procedures. Effect: Contracts for goods and service that were “covered transactions” were entered into prior to verifying that an entity was not suspended, debarred, or otherwise excluded. Questioned Costs: None Recommendation: We recommend that the School Department follows established verification procedures to ensure that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded.