Finding Text
Criteria or specific requirement: Nonfederal 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 nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All nonprocurement 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. In addition, a suspension and debarment policy is required to be in place. Condition: During testing of one vendor paid over $25,000, it was noted there was no documentation to ensure one vendor was not suspended or debarred at the time of purchase. Due to no documentation of the vendor, there was also no review of the vendor. In addition, it was noted the College does not have an approved suspension and debarment policy. Questioned costs: None Context: During our testing, CLA noted one vendor was not checked to ensure they are not suspended or debarred at the time of purchase. In addition, due to not verifying the vendor, there is no review of the vendor. Lastly, it was noted the College does not have an approved suspension and debarment policy. Cause: The control system to prevent payment to a suspended and barred vendor was not in place. Effect: The College could have paid a vendor who is suspended or barred at the time of purchase. Repeat Finding: No Recommendation: CLA recommends for every vendor being paid with federal funds a cumulative amount of $25,000 for the fiscal year to be verified and documented the vendor is not suspended or barred. In addition, CLA recommends the College to implement a suspension and debarment policy. Views of responsible officials: There is no disagreement with the audit finding.