Finding 553639 (2024-002)

Corrective Action Plan Finding No. 2024-002 – Suspension and Debarment U.S. Department of Education ALN: 93.493 Program Name: Congressional Deliverables 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 180.985 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University did not maintain formal documentation over its review of vendors for suspension and debarment. Cause: Due to turnover within the University the documentation of review was not maintained. Effect: Risk of noncompliance over the suspension and debarment compliance requirement. Questioned Costs: None Prevalence: There was no formal documentation over review for suspension and debarment Repeat Finding: This is not a repeat finding. Recommendation: We recommend that University update its policies to include formal documentation be maintained annually as evidence of its review of vendors not being suspended or debarred using the System for Award Management (SAM). Corrective Action Plan: 1. USJ will review and update its existing vendor policy to include the requirement that formal documentation be maintained annually as evidence of its review of vendors not being suspended or debarred using the System for Award Management. 2. The USJ Business Office will document a formal process consistent with the updated vendor policy to ensure efficient and effective compliance with the review of its vendor for not being suspended or debarred. Target Date of Implementation: 1. June 30, 2025 Responsible Party: Mr. James F. White, Vice President for Finance and Administration