Finding Text
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.