Finding Text
Finding 2022-001 ? Significant Deficiency Federal Agency: U.S. Department of Education Federal Program Title and ALN: Research and Development Cluster - Education Innovation and Research (84.411C) Compliance Requirement: Procurement and Suspension and Debarment Award Period: October 1, 2018 to September 30, 2023 Criteria 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. Condition/Context A suspension and debarment verification was not performed for one of the two vendors tested. Per sam.gov, there was no history of the vendor being suspended or debarred. Cause While Children's Literacy Initiative does have a requirement in its procurement policy to perform a suspension and debarment verification prior to selecting a vendor, this verification was inadvertently not performed for the noted vendor. Effect Children's Literacy Initiative could make a disbursement to a vendor that is suspended or debarred. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding The finding is not a repeat finding. Recommendation We recommend Children's Literacy Initiative remind its employees regarding its policies and procedures to perform a suspension and debarment verification prior to selecting a vendor. Views of Responsible Officials Management agrees with the finding and will follow established policies for vendor selection in the future. This specific vendor was selected to provide teacher stipend gift cards for seminar attendance and was the fastest alternative to using our existing PNC Bank gift card account. They were an established website merchant located in Pittsburgh PA with 20 years of experience and discussions with their management provided us the comfort level necessary to proceed. Management neglected to check for disbarment and will remind all staff that this is a necessary step in vendor selection.