Finding Text
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.