Finding Text
Finding 2022-002: Procurement, Suspension, and Debarment (Significant Deficiency) Federal Program: 93.224 - U.S. Department of Health and Human Services Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions, a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded. This verification may be accomplished by checking the System for Award Management (SAM) website maintained by the General Services Administration. Condition: For all disbursements tested, the Organization could not provide documentation of their verification, prior to payment, that the vendors were not suspended, debarred or otherwise excluded. Questioned Costs: $- Cause: The Organization did not require evidence of SAM checks be maintained in its vendor files. As a result, the Organization did not maintain adequate support to provide evidence that appropriate suspension and debarment searches were performed. Despite the lack of documentation, a search was performed after the fact to verify that the vendors or individuals in our sample were not suspended, debarred or otherwise excluded. Therefore, no questioned costs have been reported related to the sample that was tested. Effect or Potential Effect: The Organization was not in compliance with the procurement documentation requirements of the Uniform Guidance. As a result, the Organization could not readily provide evidence that it had assessed whether or not its vendors were suspended, debarred, or otherwise excluded. As a result, the potential for payments to suspended, debarred, or otherwise excluded vendors and individuals exists. Recommendation: The Organization should establish internal controls to ensure proper documentation is maintained as evidence to support that the Organization performed the required suspension and debarment searches on the SAM website.