Finding Text
2024 – 002 Suspension and Debarment
Federal Agency: U.S. Department of Treasury
Federal Program: Coronavirus State and Local Fiscal Recovery Funds
AL Number: 21.027
Award Period: 9/21/23 - 6/30/25
Type of Finding: Significant deficiency in Internal Control over Compliance and Compliance
Criteria or Specific Requirement
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Award requires compliance with the provisions of procurement and suspension and debarment.
The Organization should have internal controls designed to ensure compliance with these provisions.
Condition and Context
During our testing over suspension & debarment, we noted one instance in which the Organization did
not perform the suspension and debarment check prior to entering into a transaction with a vendor.
Effect
Noncompliance results in possible federal funds provided to ineligible vendors.
Questioned Costs
None
Cause
The debarment check for one vendor was not completed until after the invoice was paid.
Recommendation
We recommend that the Organization implement a process to ensure suspension and debarment checks
are performed and documentation is retained to show that the checks are occurring prior to entering into
transactions with vendors.Views of Responsible Officials
The Organization has internal staffing challenges within the accounting department in 2024 resulting in
turnover. The Organization has a process in place to check vendors against the OIG exclusion list when
the vendor is added to the accounts payable system and prior to paying the vendor. This vendor applied
the wire payment one day prior to the Organization running the check against the exclusion list. The
Organization was under the impression that the vendor would not execute the wire on that date. The
Organization did perform a suspension and debarment check subsequent to the payment being made,
and no findings were found for the vendor. We believe the payment was expedited by the vendor due to
their implementation timeline and feel this is an isolated one-time event.