Finding Text
Criteria or Specific Requirement
2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 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 and debarment, we noted the three instances in which the Organization did not perform the suspension and debarment check prior to entering into a transaction with a vendor.
Effect
The auditor noted instances of noncompliance. Noncompliance could result in possible federal funds being provided to ineligible vendors.
Questioned Costs
None identified.
Cause
The Organization lacks established internal controls and procedures over financial grant management. The Organization did not perform the suspension and debarment check prior to entering into the transactions.
Recommendation
We recommend the Organization implement a process to ensure suspension and debarment checks are performed and documentation to show that the checks are occurring prior to entering into transactions with vendors.
Views of Responsible Officials
Suspension and Debarment checks were occurring prior to a transaction with a new vendor; however, the checks were not saved. Any new vendor will have a check, and if we check them manually, we will begin to save these checks as documentation. We also implemented Compliatrics early in 2022 where we can enter our vendors into this system to do an auto check every month. It will flag us when a vendor is on the exclusion listing. Dell and NCHA were checked prior to transactions being entered into, but the documentation was not saved. These two vendors began being checked monthly through Compliatrics starting February 1, 2022. Amazon has now been entered into Compliatrics and is being checked monthly. Amazon was checked prior to using them as a vendor, but the documentation was not saved. As of June 8, 2023, Amazon is not on the exclusion list. We have begun to enter all vendors we utilize into this system.