Finding Text
2024-003 Procurement, Suspension and Debarment
Federal agency: U.S. Department of Health and Human Services
Federal program: Epidemiology Program (ALN 93.231)
Pass-through Entity: None
Federal Award Year: Year ended September 30, 2024
Criteria: The Uniform Guidance stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when entering into a covered transaction that is expected to equal or exceed $25,000.
Condition: During our testing of suspension and debarment requirements, we noted that there was no documentation that the Organization verified that certain vendors were not suspended or debarred prior to entering into the covered transaction. We did not note any vendors in our sample that appeared at sam.gov as being precluded from participating in a federally funded procurement.
Cause: The Organization does not always maintain documentation that the verification was performed.
Effect: The Organizations internal controls related to suspension and debarment were not supported in all instances to show that they were performed.
Questioned costs: None
Prevalence: The population of covered transactions equal to or greater than $25,000 included 3 vendors for the program referred to in this finding. For 2 of the 3 vendors tested, the Organization did not have documentation showing that they verified the status of the vendor prior to entering into a covered transaction. The sample size of 3 was determined using guidance in the American Institute of Certified Public Accountants Audit and Accounting Guide – Government Auditing Standards and Single Audits.
Repeat finding: No
Recommendation: We recommend the Organization verify status of all vendors prior to entering into a covered transaction and maintain supporting documentation.