Finding Text
Criteria or Specific Requirement:
In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use
its own documented procurement procedures which reflect applicable State, local, and tribal laws
and regulations, provided that the procurements conform to applicable federal law and the
standards identified in General Procurement Standards. Additionally, §200.318(i) states that the
non-federal entity must maintain records sufficient to detail the history of the procurement. These
records are required to include but are not necessarily limited to the following: rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis
for the contract price. All procurement transactions must be conducted in a manner providing full
and open competition consistent in accordance with §200.319 and must be performed using the
appropriate procurement method as outlined in §200.320.
In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot
enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or
otherwise excluded from or ineligible for participation in federal assistance programs or activities.
Non-federal entities must either check for exclusions in the System for Award Management (SAM);
collect a certification from the entity, or add a clause or condition to the covered transaction with
the entity prior to entering into a covered transaction with a non-federal entity. In addition, in
accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions
(other than no-cost time extension) with any excluded person, or under which an excluded person
is a principal, unless the non-federal entity obtains an exception under §180.135.
Condition: During our compliance testing of the procurement compliance requirement, with respect
to ALN # 19.345, for one (1) sample of eleven samples selected for testing, the Organization
amended the contract to extend the end date and adjust pricing before verifying and documenting
that the vendor was not suspended or debarred. For ALN #19.501, for two (2) samples of the three
samples tested, the Organization signed amendments in November 2023 and July 2024, before
verifying and documenting that the vendor was not suspended or debarred. The last verification was
performed in May 2022.
Cause: The Organization did not perform proper suspension and debarment validations when the
amendment to the agreement was signed.
Effect: Failure to perform procurement procedures in accordance with a written policy that
complies with Procurement Procedures as outlined in the Uniform Administrative Requirements
could result in the procurement being disallowed. Failure to timely verify that a vendor is not
suspended or debarred could result in transactions involving unreasonable costs or result in
unintentionally entering into a contract with an entity that is barred from performing work for the
U.S. government.
Questioned Costs: None.
Context: This is a condition based on testing of the Organization’s compliance with specified
requirements. The prevalence of these findings is detailed in the condition section above. The
samples were selected using a random sampling method.
Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2023-
003 in the 2023 Schedule of Findings and Questioned Costs.
Recommendation: We recommend that management strengthen the procurement policy to align
with the Procurement Procedures outlined in the Uniform Administrative Requirements.
Additionally, we suggest providing all staff with additional training on this policy to ensure
compliance in the future.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.