Finding Text
U.S. Department of Health and Human Services - 93.432 Center for Independent Living
2024-006 Lack of Documentation for Suspension and Debarment Verification
Criteria: Per 2 CFR §180.300 and 2 CFR §200.214, entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify a vendor's status using SAM.gov and maintain documentation as evidence of compliance with this requirement.
Condition: During our audit procedures related to procurement under federal awards, we noted that the League did not maintain documentation showing that vendors and contractors paid with federal funds were checked against the System for Award Management (SAM.gov) to verify they were not suspended or debarred. While management stated that vendors are routinely reviewed on SAM.gov prior to engagement, there was no evidence, such as printouts, screenshots, or other records, retained to support that the checks had occurred.
Cause: The League did not have a formal process in place to document and retain evidence of suspension and debarment checks. Verification procedures were informal and not consistently recorded.
Effect: Without documented evidence of suspension and debarment checks, the League cannot demonstrate compliance with federal procurement requirements. This increases the risk that federal funds could be paid to ineligible vendors, which may result in questioned costs or noncompliance findings.
Questioned Costs: None noted.
Recommendation: We recommend the League establish and implement a formal policy requiring documentation of all SAM.gov suspension and debarment checks for vendors paid with federal funds. This may include saving screenshots or printouts of the SAM.gov search results, retaining vendor verification logs, or using automated tools if available. Documentation should be maintained in accordance with federal record retention requirements.
Views of Responsible Officials and Planned Corrective Actions: See corrective action plan on page 50.