FAC Explorer

Finding 570433 (2023-009)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2025-07-02
Audit: 361393
Organization: College of Micronesia - Fsm (FM)
Auditor: Ernst & Young

AI Summary

  • Core Issue: The College failed to verify the debarment or suspension status of entities before engaging in covered transactions, violating 2 CFR section 180.300.
  • Impacted Requirements: Compliance with federal regulations regarding procurement and ensuring that business partners are not excluded or disqualified.
  • Recommended Follow-Up: Develop a formal procedure for verifying entity status, including regular checks against SAM.gov and other relevant resources.

Finding Text

Finding No.: 2023-009 Federal Agency: U.S. Department of Education AL Program: COVID 19 - 84.425 Education Stabilization Fund Research and Development Cluster Federal Award No.: Various Area: Procurement, Suspension and Debarment Questioned Costs: $--- Criteria: 2 CFR section 180.300 requires entities that enter into a covered transaction must verify that the person with whom they intend to do business is not excluded or disqualified by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: For 16 (or 100%) of 16 transactions tested, the College did not perform the required verification of persons required by 2 CFR section 1800.300. No questioned cost was identified as subsequent checking of the samples in SAM.gov did not result in identification of suspended or debarred individuals. No questioned cost was identified as subsequent look up of the samples against SAM.gov did not identify a suspended or debarred individual. Cause: There is no formalized procedure in place for verifying the debarment, suspension, or exclusion status of entities prior to entering into covered transactions. Effect or potential effect: The College is in noncompliance with the applicable requirements. Recommendation: The College should develop and implement a formal procedure for verifying the debarment, suspension, or exclusion status of entities prior to entering into covered transactions, which includes regular checks against the System for Award Management (SAM) database and other relevant resources. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Corrective Action Plan

Finding 2023-09 - Procurement, Suspension, and Debarment Recommendation The College should develop and implement a formal procedure for verifying the debarment, suspension, or exclusion status of entities prior to entering into covered transactions, which includes regular checks against the System for Award Management (SAM) database and other relevant resources. Response The College acknowledges the findings and is fully committed to strengthening its procurement process by implementing the following strategic improvements: 1) Incorporating the verification of the status of contractors, vendors, and other third parties in SAM.gov into the procurement procedure. Procurement staff will conduct verification prior to issuance of any purchase order and document SAM.gov screening on all procurement files. Contact: Director of Procurement & Property Management Office Completion Date: September 30, 2025

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 570428 2023-004
    Significant Deficiency
  • 570429 2023-005
    Significant Deficiency
  • 570430 2023-006
    Material Weakness
  • 570431 2023-007
    Material Weakness
  • 570432 2023-008
    Material Weakness
  • 570434 2023-009
    Significant Deficiency
  • 570435 2023-009
    Significant Deficiency
  • 570436 2023-009
    Significant Deficiency
  • 570437 2023-009
    Significant Deficiency
  • 1146870 2023-004
    Significant Deficiency
  • 1146871 2023-005
    Significant Deficiency
  • 1146872 2023-006
    Material Weakness
  • 1146873 2023-007
    Material Weakness
  • 1146874 2023-008
    Material Weakness
  • 1146875 2023-009
    Significant Deficiency
  • 1146876 2023-009
    Significant Deficiency
  • 1146877 2023-009
    Significant Deficiency
  • 1146878 2023-009
    Significant Deficiency
  • 1146879 2023-009
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $9.33M
84.425 Education Stabilization Fund $1.26M
10.511 Smith-Lever Extension Funding $772,212
15.875 Economic, Social, and Political Development of the Territories $671,227
84.047 Trio Upward Bound $596,043
11.307 Economic Adjustment Assistance $424,597
11.028 Connecting Minority Communities Pilot Program $341,775
84.044 Trio Talent Search $340,205
93.236 Grants to States to Support Oral Health Workforce Activities $289,130
10.203 Payments to Agricultural Experiment Stations Under the Hatch Act $190,567
10.322 Distance Education Grants for Institutions of Higher Education in Insular Areas $83,237
10.514 Expanded Food and Nutrition Education Program $56,096
10.308 Resident Instruction, Agriculture, and Food Science Facilities and Equipment Grants $43,325
47.076 Stem Education (formerly Education and Human Resources) $26,110