FAC Explorer

Finding 561227 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-05-21
Audit: 356865
Organization: Southeast Alaska Watershed Coalition (AK)
Auditor: Elgee Rehfeld LLC

AI Summary

  • Core Issue: SAWC failed to verify that contractors and subrecipients were not suspended or debarred before entering into contracts or subawards.
  • Impacted Requirements: Compliance with 2 CFR Part 180 and 2 CFR 200.332, which mandate checks for suspension and debarment for federal funding recipients.
  • Recommended Follow-Up: Implement a process to collect certifications from contractors/subrecipients or include suspension and debarment clauses in contracts.

Finding Text

2024-001 Significant Deficiency in Internal Controls over Compliance and Compliance, Other Matter – Procurement (suspension and debarment) Agency: U.S. Department of the Interior Program(s) and Federal Award Listing Number(s): Partners for Fish and Wildlife ALN: 15.631 FAIN: FA22AC02756, FA23AC02476 New or Repeat: New Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Per 2 CFR Part 180, as referenced in 2 CFR Part 1400, for any contract expected to total $25,000 or more, a recipient of federal funds must confirm that the contractor is not suspended or debarred from receiving federal funds. Per 2 CFR 200.332, a pass-through entity must verify that the subrecipient is not suspended, debarred, or otherwise excluded from receiving federal funds in accordance with 2 CFR 180.300. Condition: SAWC was not able to provide supporting documentation indicating that it had verified that contractors and subrecipients were not suspended or debarred prior to contracting with, or making a subaward to, the entities. Cause: Internal controls were designed, but not sufficiently implemented to ensure that documentation of the check for suspension and debarment was retained. Effect: SAWC could have contracted with, or made a subaward to, an entity that was suspended or debarred. Context: We tested 100% of the procurement population. For three of the three contractors/subrecipients tested, we were not able to verify that SAWC confirmed the contractor/subrecipient was not suspended or debarred prior to entering into the transaction. Questioned costs: There are no questioned costs associated with this finding. Recommendation: We recommend SAWC consider either collecting a certification regarding suspension and debarment from contractors/subrecipients or adding a suspension and debarment clause or condition to contracts and subawards. View of responsible officials: Management concurs with this finding, see corrective action plan.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 561225 2024-001
    Significant Deficiency
  • 561226 2024-002
    Significant Deficiency
  • 561228 2024-002
    Significant Deficiency
  • 1137667 2024-001
    Significant Deficiency
  • 1137668 2024-002
    Significant Deficiency
  • 1137669 2024-001
    Significant Deficiency
  • 1137670 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
15.631 Partners for Fish and Wildlife $301,679
15.685 National Fish Passage $124,190
10.902 Soil and Water Conservation $59,614
66.605 Performance Partnership Grants $22,575
11.438 Pacific Coast Salmon Recovery Pacific Salmon Treaty Program $16,352
15.630 Coastal $16,023
11.463 Habitat Conservation $11,681
10.680 Forest Health Protection $6,038
10.665 Schools and Roads - Grants to States $5,164
10.683 National Fish and Wildlife Foundation $85
10.675 Urban and Community Forestry Program $-234