Finding 567102 (2024-001)

NATIONAL SCIENCE FOUNDATION AND DEPARTMENT OF ENERGY 2024-001 Construction of the Vera C. Rubin Observatory under the MREFC – Assistance Listing No. 47.049 Management, Operations and Maintenance of Vera C. Rubin – Assistance Listing No. 47.049 LSST Commissioning Services for SLAC (DOE) – Assistance Listing No. 81.RD Recommendation: We recommend AURA enhance controls to ensure an adequate process is in place to review potential vendors to determine they are not suspended or debarred and to ensure documentation to support this is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Plan: The Association of Universities for Research in Astronomy, Inc. (AURA) agrees with the finding. Although no vendors were found to be suspended or debarred, we acknowledge the need to strengthen our internal controls to ensure documentation is consistently maintained to evidence compliance with federal suspension and debarment requirements. AURA has taken the following steps to address this finding: 1. Control Enhancement: AURA Procurement procedures already require that verification of vendor eligibility (via the SAAS E2Open screening portal) be performed and documented prior to the issuance of any purchase order or contract. We implemented enhancements in late FY24 early FY25 to the process and will be updating our procurement manual and Carina record format to reflect this change for FY25. AURA has strengthened screening capture and verification as part of our enhanced Vendor Management process. - For all new vendors, the Procurement team submits the request for a new vendor setup through a JIRA project (which creates a tracking ticket). The record then must have the required information validated – a screening against the debarred/sanctioned/excluded parties lists (SAAS E2Open/Amber Road) as well as vendor-confirmed validation of minimally required information. - For all existing vendors, AURA pulled the full vendor table from Costpoint and screened all vendors effective October 2024. - For all existing vendors, AURA Procurement is reviewing each existing vendor record to validate current information or if not used for 2+ years, inactivating the vendor record. Reactivation will require the new vendor process to affirm all information and process compliance. AURA is working through processes to better document screening to align with the functionality and processes within E2Open’s software. We are currently working to update our Costpoint vendor records to also include the E2Open/Amber Road partner number (the individual tracking number assigned by the screening software to each vendor screened). This process will be on-going, resources permitting. 2. Staff Training: AURA Procurement staff will receive refresher training on federal procurement requirements, including the importance of suspension and debarment reviews and related documentation requirements, as well as a review of the updated processes at AURA. This training will be completed by July 31, 2025. 3. Monitoring and Oversight: Periodic internal reviews will be conducted by the Procurement team to ensure consistent adherence to the updated procedures. Any exceptions will be addressed promptly with corrective measures. Responsible Individual: Ken Kadlec, Director of Contracts and Compliance Expected Completion Date: Other than full existing vendor review (1.3), completion by July 2025.