Finding 577179 (2023-001)

Finding 2023-001 Identification of the federal program Procurement and Suspension and Debarment – Significant Deficiency in Internal Control Over Compliance Assistance Listing Number 84.356A Alaska Native Educational Programs Grant number: S356A210034 Assistance Listing Number 84.299A Indian Education – Special Programs for Indian Children Grant number: S299A200075 Criteria or specific Requirement Condition Cause Effect or potential effect Questioned costs Context Identification as a repeat finding Recommendation Views of Responsible Official Internal controls should be designed and implemented to provide reasonable assurance that an entity with which Alaska Native Heritage Center (the Center) plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded for covered transactions under Uniform Guidance. Documentation that vendors are not debarred, suspended or otherwise excluded were not retained in the Center’s procurement files and thus, auditors were not able to test that relevant internal controls were operating effectively. Management lacked verification or documentation regarding the exclusion or debarment status of vendors for covered transactions under Uniform Guidance. Although former employees confirmed they had checked the system, management was unable to provide evidence to support their verification. Management might enter into a covered transaction with a vendor that is debarred, suspended or otherwise excluded. None Auditors were not able to verify internal controls over sampled procurements, since no documentation was retained. Not a repeat finding We recommend that management retain evidence of review that prospective vendors and suppliers are not on the suspension and debarment list for covered transactions under Uniform Guidance. We also recommend that checking the system is part of the grant on-boarding process. Management agrees with this finding. The Procurement Procedure has been updated to include affirmative action of the Grant Program Department performing a suspension and department review of all vendors to be paid using federal resources and creating documentation to verify compliance with this process.