Finding Text
Finding 2022-002: Procurement and Suspension and Debarment Identification of federal program: Program Title: Agriculture Research Basic and Applied Research Assistance Listing Number: 10.001 Award Identification: CA 59-8082-0-001 Federal Agency: U.S. Department of Agriculture, Agriculture Research Service Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During testing for the Fund?s controls on compliance over procurement and suspension and debarment, the Fund could not provide a procurement policy that is in compliance with prescribed standards in the Uniform Guidance. Additionally, suspension and debarment verifications were not performed prior to entering a covered transaction. Cause: The Fund has not updated its procurement policy to fully conform with Uniform Guidance, including policies over suspension and debarment. Effect: The Fund was not in compliance with the procurement policy requirements of Uniform Guidance, specifically around suspension and debarment. Questioned Costs: None Context: The Fund currently does not have a procurement policy that fully complies with Uniform Guidance requirements addressed in Chapter 2 Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Repeat finding: No Recommendation: The Fund should ensure its documented procurement procedures conform to the procurement standards identified in 2 CFR section ?? 200.317 through 200.327, and also address suspension and debarment. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.