Finding 579113 (2023-002)

2023-002 Noncompliance with Procurement, Suspension, & Debarment Standard – 21.027 (Significant Deficiency – Noncompliance) Criteria – 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.214 prohibits non-federal entities from contracting with parties that are suspended or debarred under covered transactions. Condition and Context – Audit procedures revealed that there was not a process in place to formally document the review of the contracted entity for suspension and debarment prior to entering into the agreement. Cause – The Organization does not have a formal process to document suspension and debarment. Management was unaware of the requirement, though it was clear that management thoughtfully considered the contractor’s reputation and determined that the contractor was suited for the agreement. Effect –The Organization did not perform its review of suspension and debarment for this agreement, though the contractor was found to not be on prohibited lists at annual review. Questioned Costs – None Recommendations – Management should strengthen their processes, controls, and review over suspension, and debarment processes and ensure compliance with Uniform Administrative Requirements. Views of Responsible Officials and Planned Corrective Actions – Request constructions manager to check suspension and debarment of all subcontractors prior to hire if project has not already been started.