Finding Text
Criteria: Per 2 CFR Section 200.214 and Appendix II to Part 200, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify that a subrecipient is not suspended or debarred at the time of the award, either by checking the SAM.gov exclusion list, collecting a certification or including appropriate contract clauses.
Condition and context: During testing of the Alliance’s controls on compliance over subrecipient monitoring and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check prior to making a subaward.
Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check prior to issuing subawards.
Effect: The Alliance was not fully in compliance with the subrecipient monitoring and suspension and debarment check requirements of the Uniform Guidance.
Questioned Costs: None.
Identification as a Repeat Finding: N/A.
Recommendation: We recommend that the Alliance review its current processes and controls over subrecipient monitoring and suspension and debarment to ensure all required documentation is retained and available.
Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.