Finding Text
Federal Agency: U.S. Agency for International Development
Federal Program Name: Collaboration for African Biodiversity (ABCG III)
Assistance Listing Number: 98.001
Federal Award Identification Number and Year: 7200AA20FA0032 - 2023
Pass-Through Agency: World Resources Institute
Pass-Through Number(s): FAA-7200AA20FA0032
Award Period: October 1, 2020 through September 30, 2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance and Compliance
Criteria or specific requirement: 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 certification from the entity, or add a clause or condition to the covered
transaction with the entity prior to entering into a covered transaction. 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 nonfederal
entity obtains an exception under §180.135.
Condition: For one sample for award FAA-7200AA20FA0032, we noted that there was no evidence
showing that the suspension and debarment verification occurred before the transaction with the vendor
was initiated, although evidence suggested that it had been completed thereafter, and the vendor was not
suspended or debarred.
Questioned costs: None
Context: This is a condition based on testing of AWF's compliance with specified requirements. The
prevalence of the finding is detailed in the condition section above.
Cause: AWF personnel did not retain proper documentation to ensure proper suspension and debarment
validations were performed.
Effect: Failure to perform procurement procedures in accordance with AWF's documented policies and
procurement procedures outlined in the Uniform Administrative Requirements could result in the
procurement being disallowed. Failure to 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 federal government.
Repeat Finding: No
Recommendation: We recommend management to ensure retention of evidence to include dates of when
suspension and debarment verifications are performed.
Views of responsible officials: There is no disagreement with the audit finding.