Finding Text
2024 – 003 Procurement, Suspension, and Debarment
Federal Agency: U.S. Department of Veteran Affairs
Federal Program Name: Supporting Services for Veteran Families Program
Assistance Listing Number: 64.033
Federal Award Identification Number and Year: 14-IN-200, 14-IN-200SS, 14-IN-200-LT
Award Period: October 1, 2022 – September 30, 2025
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have a comprehensive procurement policy in compliance with the federal regulations. The Organization also did not have documentation to support that internal controls were performed to ensure vendors were not suspended or debarred prior to entering into the contract.
Questioned costs: None
Context: During our testing, it was noted that the Organization did not maintain documentation regarding its procurement transactions and evaluation of those transactions against a comprehensive procurement policy. In addition, the Organization did not maintain documentation illustrating that it had reviewed vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. This exception was noted for two (2) of the two (2) items tested, however, we were able to verify that the selected vendors were not suspended or debarred.
Cause: The Organization did not establish a comprehensive procurement policy. In addition, the Organization was unable to locate documentation to support the performance of procedures to ensure vendors were not suspended or debarred.Effect: Because of the lack of procurement policy, the auditor was not able to validate compliance with the federal procurement policies. However, the auditor noted no instances of noncompliance with the suspension, and debarment provisions. For both, procurement and suspension and debarment, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance.
Repeat Finding: No.
Recommendation: We recommend the Organization develops a comprehensive procurement policy that complies with the federal regulations and that the Organization enhances controls to ensure an adequate process is in place to review potential vendors to determine they are not suspended or debarred and to ensure documentation to support this is maintained.
Views of responsible officials: There is no disagreement with the audit finding.