Finding 573697 (2024-001)

Federal Agency: U.S. Department of the Interior - BOR Federal Program Name: Providing Water to At-Risk Natural Desert Terminal Lakes Assistance Listing Number: 15.508 Federal Award Identification Year: 2024 Pass-Through Agency: National Fish and Wildlife Foundation Award Period: 7/1/19-9/30/24 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.403(a) - When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: For eight procured vendors that were selected, verification of subrecipient's suspension or debarment status was not performed. Context: A nonstatistical sample of 21 out of 173 procured vendors were selected for testing for the above program. The condition noted above was identified during our procedures over WBC's procured vendors. Effect: WBC did not verify suspension or debarment status timely, which could result in procuring a vendor which is potentially suspended or debarred. Cause: WBC did not consistently ensure that Suspension or Debarment status was verified timely before naming procuring the vendor. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that WBC strengthen its current policies and procedures to ensure that Suspension and Debarment Status is verified for each vendor subject to verification of suspension and debarment verification according to WBC's Procurement policy. Management’s Views: See separate corrective action plan.