Finding Text
Finding Number: 2022-003 Federal Programs: CFDA 14.850 ? Public and Indian Housing CFDA 93.600 ? Head Start (Cluster) Condition: In some cases, the personnel in charge of the procurement process make the verification process on the list of suspended or debarment vendors/contractors, but not for all the cases where is applicable. The audit test reflected that there were no vendors or contractors that have been suspended or debarred. Criteria: (a) The CFR ?200.214 -Suspension and debarment establish that non-Federal entities are subject to the nonprocurement debarment and suspension regulations in which restrict the awards, subawards, and contract with certain parties that are debarred, suspended, or otherwise excluded form or ineligible for participation in assistance program or activities. (b) The notice of award?s standards terms for CFDA 93.600 establishes that awards are subjects to the requirements of the Department of Health and Human Services (HHS) Grants Policy Statements, which require that a recipient complied with the requirements of suspension and debarment. In addition, the recipient must include a requirement in any covered transaction at the next lower tier to comply with those same regulatory provisions. One of those provisions is that, before entering into a covered transaction, the recipient or lower-tier participant must verify that the entity is not suspended or debarred or otherwise excluded. Cause: The BGCPR's fiscal manual did not include the process to be performed for the verification of the status of vendors and contractors with the Federal Government. Effect or potential effect: Lack of formal procedures to assure that the vendors/contractors were not suspended or debarred may lead to an unallowable cost. Recommendation: BGCPR should be establish a formal procedure to assure that an independent check for recurring vendors must be performed at least once a year. For non-recurring vendors, new or large contracts, and for change orders to existing contracts, the requirement should be met prior to entering into the contract or making contract amendments.To avoid non-compliance, the review for suspension and debarment compliance should be part of the internal controls, policies, and procedures. It should also be part of the review process relating to quotes or bidding requirements.