FAC Explorer

Finding 620672 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-19
Audit: 45286
Organization: University of Denver (CO)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The University failed to verify vendor suspension or debarment status before entering into contracts with five out of eight vendors tested.
  • Impacted Requirements: Non-Federal entities must ensure vendors are not suspended or debarred as per 2 CFR section 180.995.
  • Recommended Follow-Up: Establish a clear policy and procedure for verifying vendor status prior to transactions to ensure compliance.

Finding Text

Criteria or specific requirements: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters a covered transaction with an entity, 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 can be accomplished through reviewing SAM.gov, obtaining a certification from the vendor, or through a clause or condition within the signed contract prior to entering into the transaction. Condition: We noted that five out of eight vendors selected for testing were not verified that they have not been suspended or debarred prior to entering into the transaction. Internal controls did not detect these instances of noncompliance. The University confirmed that these vendors were not currently suspended or debarred through verification during audit fieldwork, but that was subsequent to the transaction date. Questioned costs: None. Context: The University was not following a policy and procedure to verify a vendor?s suspension and debarment status. The University was not able to provide evidence that verification of the suspension and debarment status occurred prior to the transaction. Cause: The University did not have a policy in place to verify a vendor?s suspension and debarment status prior to entering into a covered transaction. As a result, the University did not review SAM.gov, obtain a certification from the vendor, or obtain a clause or condition within the signed contract prior that the vendor was not suspended or debarred prior to entering into the transaction. Effect: The University is not in compliance with suspension and debarment requirements for its federal programs. In addition, it could inadvertently pay a vendor who is suspended and debarred from federal programs. Repeat Finding: No.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 44224 2022-001
    Significant Deficiency
  • 44225 2022-001
    Significant Deficiency
  • 44226 2022-001
    Significant Deficiency
  • 44227 2022-001
    Significant Deficiency
  • 44228 2022-001
    Significant Deficiency
  • 44229 2022-001
    Significant Deficiency
  • 44230 2022-001
    Significant Deficiency
  • 44231 2022-001
    Significant Deficiency
  • 44232 2022-001
    Significant Deficiency
  • 44233 2022-001
    Significant Deficiency
  • 44234 2022-001
    Significant Deficiency
  • 44235 2022-001
    Significant Deficiency
  • 620666 2022-001
    Significant Deficiency
  • 620667 2022-001
    Significant Deficiency
  • 620668 2022-001
    Significant Deficiency
  • 620669 2022-001
    Significant Deficiency
  • 620670 2022-001
    Significant Deficiency
  • 620671 2022-001
    Significant Deficiency
  • 620673 2022-001
    Significant Deficiency
  • 620674 2022-001
    Significant Deficiency
  • 620675 2022-001
    Significant Deficiency
  • 620676 2022-001
    Significant Deficiency
  • 620677 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loan Program $174.21M
84.425 Covid-19 - Education Stabilization Fund - Student Portion $6.13M
84.425 Covid-19 - Education Stabilization Fund - Institutional Portion $6.10M
84.038 Federal Perkins Loan Program $5.34M
84.063 Federal Pell Grant Program $4.34M
84.033 Federal Work Study Program $1.96M
93.648 Child Welfare Services Training Grants $1.46M
84.007 Federal Supplemental Education Opportunity Grant Program $1.25M
93.837 Cardiovascular Diseases Research $1.04M
47.049 Mathematical and Physical Sciences $974,478
93.732 Mental and Behavioral Health Education and Training Grants $855,826
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $602,704
84.206 Javits Gifted and Talented Students Education $509,553
84.324 Research in Special Education $425,235
93.060 Sexual Risk Avoidance Education $355,816
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $355,102
93.394 Cancer Detection and Diagnosis Research $327,554
84.326 Special Education Technical Assistance and Dissemination $308,592
84.327 Special Education Educational Technology Media, and Materials for Individuals with Disabilities $300,234
93.866 Aging Research $253,856
97.132 Financial Assistance for Targeted Violence and Terrorism Prevention $218,861
20.701 University Transportation Centers Program $194,432
93.604 Assistance for Torture Victims $167,560
12.420 Military Medical Research and Development $162,009
93.865 Child Health and Human Development Extramural Research $157,191
47.070 Computer and Information Science and Engineering $154,701
84.305 Education Research, Development and Dissemination $152,347
14.536 Research and Evaluations, Demonstrations, and Data Analysis and Utilization $150,322
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $138,722
45.161 Promotion of the Humanities Research $125,759
16.830 Girls in the Juvenile Justice System $122,957
21.008 Low-Income Taxpayer Clinic $102,603
93.242 Mental Health Research Grants $99,428
84.379 Teacher Education Assistance for College and Higher Education (teach) Grants $90,528
94.026 National Service and Civic Engagement Research Competition $83,047
93.434 Every Student Succeeds Act/preschool Development Grants $76,657
93.838 Lung Diseases Research $68,459
45.163 Promotion of the Humanities Professional Development $63,478
15.946 Cultural Resources Management $57,768
47.041 Engineering Grants $56,150
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $52,926
81.049 Office of Science Financial Assistance Program $52,213
47.074 Biological Sciences $47,837
93.958 Block Grants for Mental Health Services $46,248
15.933 Preservation of Japanese American Confinement Sites $40,046
45.024 Promotion of the Arts Grants to Organizations and Individuals $39,579
16.560 Justice Research, Development and Evaluation $38,462
47.079 Office of International Science and Engineering $38,113
45.313 Laura Bush 21st Century Librarian Program $37,405
43.001 Aerospace Education Services Program $36,528
93.859 Biomedical Research and Research Training $31,631
47.050 Geosciences $30,391
81.087 Renewable Energy Research and Development $30,207
16.825 Smart Prosecution Initiative $30,055
12.800 Air Force Defense Research Sciences Program $29,115
93.879 Medical Library Assistance $27,809
93.969 Geriatrics Workforce Enhancements Program $25,021
15.945 Cooperative Research and Training Programs Resources of the National Park System $24,878
84.016 Undergraduate International Studies and Foreign Language Programs $21,874
93.855 Allergy and Infectious Diseases Research $21,241
93.279 Drug Abuse and Addiction Research Programs $17,772
93.928 Special Projects of National Significance $17,009
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $16,128
45.024 Dance Gap Grant $15,000
47.076 Education and Human Resources $11,626
91.005 Priority Grant Competition $11,053
16.320 Services for Trafficking Victims $5,879
47.075 Social $5,012
12.431 Basic Scientific Research $4,340
45.312 National Leadership Grants $4,295
20.215 Highway Training and Education $3,506
16.812 Second Chance Act Reentry Initiative $3,426
45.129 Promotion of the Humanities Federal/state Partnership $1,100
93.191 Graduate Psychology Education $462
11.417 Sea Grant Support $196
93.600 Head Start $169
93.658 Foster Care_title IV-E $122
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $0