Finding
The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed, however the evidence of the search of sam.gov was not retained.
Corrective Actions Taken or Planned
MDIC acknowledges the importance of retaining documentation to demonstrate compliance with federal procurement requirements, specifically those related to suspension and debarment under 2 CFR 200.214. While SAM.gov checks were consistently conducted prior to vendor engagement, the absence of retained search documentation was due to internal oversight and not a failure in performing the checks. As a small organization without a centralized procurement department, we had not previously formalized the documentation requirement in our procedures. Our contracts are also reviewed by the Legal team and each contract has a language around debarment and suspension of firms. To address this finding, MDIC has taken the following corrective actions:
Policy and Procedure Update
As of June 2025, our procurement procedures have been updated to require documentation (PDF printout or screenshot) of each SAM.gov search to be retained in the corresponding vendor file.
Procurement Checklist Enhancement
Our internal procurement checklist now includes a mandatory step confirming that the SAM.gov verification has been completed and documented.
Training Implementation
All staff involved in procurement and contracting processes received targeted training in June 2025 to reinforce the importance of documenting compliance steps, particularly suspension and debarment verifications.
Ongoing Monitoring
A periodic internal review process has been introduced whereby a sample of vendor files will be reviewed quarterly to ensure documentation of SAM.gov checks is properly maintained.
Contact Person Responsible
Tariq Bahich
Senior Director Finance
Anticipated Completion Date
Corrective actions were completed as of June 4, 2025, and are now fully integrated into MDIC's procurement process.