Finding Text
Federal Program Name: Research and Development Cluster: Uniformed Services
University Medical Research Projects
Federal Agency: U.S. Department of Defense
Federal Assistance Listing Number: 12.750
Criteria or Specific Requirement: Procurement, Suspension and Debarment
Condition: The Organization’s policies do not contain adequate documentation to
demonstrate compliance with federal procurement, and suspension and debarment
regulations.
Effect: Without adequate procurement policies and documentation of suspension and
debarment checks, the auditee may inadvertently award contracts to ineligible vendors.
Questioned Costs: None
Context: The Organization’s documented procurement policies do not contain all of the
specific requirements of 2 CFR sections 200.318 through 200.326. Additionally, the
Organization’s policies do not contain all the specific requirements of 2 CFR sections 180
and 200.14 regarding suspension and debarment.
Cause: The writing of the policy did not take into account the federal procurement,
suspension and debarment regulations which are required to be incorporated for items
procured with federal funds.
Repeat Finding: No
Recommendation: We recommend that the Organization revise its policies to
incorporate all required elements of the federal procurement, suspension and debarment
regulations.
Views of Responsible Officials and Planned Corrective Action: The Organization
agrees with the comment and will revise its policies to incorporate all required elements
of the federal procurement, suspension and debarment regulations.