Recommendation: We recommend the Organization strengthen its policies and procedures to ensure procurement and suspension and debarment is adequately documented for that goods and services purchased in accordance with Uniform Guidance and other federal guidelines. In addition, the Organization should verify that all vendors under covered transactions are not listed on the excluded parties list system by performing a search on sam.gov and maintaining the results of such search in the vendor’s file.
Grantee Response and Corrective Action Plan 2023-002: In response to the audit finding under 2 CFR part 180 regarding the necessity to verify suspension or debarment status in compliance with the excluded parties list system, it is acknowledged that while the Center for Black Women’s Wellness did not previously have a formal policy specifically addressing suspension and debarment, our practices have nonetheless complied with the requirements. Recognizing the importance of formalizing these practices into policy, we are committed to developing and implementing a comprehensive policy that explicitly addresses these checks. This initiative will be integrated with our existing compliance frameworks to ensure consistent adherence across all procurement activities. In line with our recent enhancements in internal controls, including the engagement of a Contractual CFO in 2024, this policy will reinforce our ongoing efforts to uphold the highest standards of compliance and accountability in all our operations.
Responsible Parties: Jemea Dorsey, CEO
Date Corrected: April 30, 2024