Finding Text
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires that when a non-federal entity plans to enter 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 Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (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 of a sample of seven vendors subject to AFAAC Suspension and Debarment controls, we noted two instances where there was a lack of evidence that AFAAC verified that the vendor was not suspended or debarred before entering into a covered transaction with those vendors during fiscal year 2022. We also noted two instances where the suspension and debarment check was not performed annually. Questioned Costs: None Context: Two vendors, out of our sample of seven, were found to have no evidence of verification that the vendor was not suspended or debarred. Also, two vendors were found to not have an annual verification that the vendor was not suspended or debarred. We did later verify the vendors were not suspended or debarred. Cause: Due to turnover within the procurement department, documentation supporting the performance of suspension and debarment compliance checks could not be located. Effect: Without maintaining supporting evidence that suspension and debarment procedures were performed over all applicable vendors, the Organization cannot support that the federally required procedures were performed and could potentially contract with vendors who are suspended or debarred, causing AFAAC to be out of compliance with regulations. Repeat Finding: No. Recommendation: We recommend the Organization maintain evidence of suspension and debarment procedures to support compliance to federal regulations and to ensure that all potential vendors are not suspended or debarred. Also, we recommend that the Organization expand its purchasing procedures to add suspension or debarment certification and verification to all Organization purchase orders to ensure transactions in all funds are being verified for current suspension or debarment. Views of Responsible Officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response.