Finding Text
Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed for one entity. Context: The University entered into covered transactions with six entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed for one entity. We re-performed the verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with obtaining or retaining documentation supporting compliance with the policies and procedures. Effect: Failure to perform and retain documentation of the procurement process could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procurement policy for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the department to ensure that the required procedure for verification of Suspension and Debarment is consistently conducted and evidence of such procedure is maintained. The OSP Office will strengthen its policies and procedures so that the SAM screenshot for all covered transactions is complete and retained. The Principal Investigator should work collaboratively with the OSP to ensure that the documentation for suspension and debarment for vendors meeting this requirement is obtained and maintained. The Manager for Grants and Contracts will be sure to check the SAM.gov for suspension and debarment and will maintain the documentation. The Assistant VP of the Office of Sponsored Projects will review the documentation.