Finding Text
2024-001 Suspension and Debarment
Finding Type: Material Weakness in Internal Controls over Compliance and Compliance
Federal Program Title and AL Number: The Emergency Food Assistance Program (TEFAP) Commodity Credit Corporation Eligible Recipient Funds (10.187)
Criteria: Per Title 2 CFR § 180.300, non-federal entities that enter into a covered transaction with an entity at a lower tier are required to verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Covered transactions includes all non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount.
Condition and context: As part of our suspension and debarment testing, and in order to determine compliance with the requirements, we verified that the debarment verification check for subrecipient agencies were performed prior to entering into agreements with these agencies. For 24 out of 25 non-statistical samples, the verification check was performed subsequent to when the Food Bank entered into the contract with the agency. None of the agencies selected were suspended or debarred.
Cause: The Food Bank did not have controls in place to ensure the debarment verifications were performed when entering into agreements with agencies.
Effect: The Food Bank was not able to demonstrate compliance with 2 CFR § 180.300.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Food Bank implement controls to ensure verification checks are performed prior to entering into agreements with agencies.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.