Finding Text
Finding 2024-001 – Procurement, suspension and debarment
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000.
A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person.
Condition: During fiscal year 2024, the Organization contracted with one vendor for services who was paid more than $25,000. There was no evidence documenting that this vendor had been checked for suspension and debarment prior to payment.
Cause: The Organization was aware of the requirement, the verification appears to have been an oversight.
Effect: Without verifying whether a vendor has been suspended or debarred prior to payment, the Organization faces a heightened risk that they are expending federal dollars to excluded parties.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization perform and document each verification on vendors over $25,000 prior to funds being disbursed. An alternative would be for the standard contract to address suspension and debarment and obtain the certification from the vendors at the time the contract is executed.
Response: As of the release of this audit, NFFCMH has 1) collected a Certification from the specific vendor verifying that the Vendor is not excluded or disqualified, 2) going forward the Organization will include a clause to that specific vendor to maintain that status, and 3) NFFCMH will perform a SAM search on the first day of each contract start and renewal date going forward for all applicable vendors.