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.