Finding Text
Finding 2022-005: Crime Victim Assistance Suspension and Debarment Procedures U.S. Department of Justice – Crime Victim Assistance – ALN 16.575 (Similar repeat finding, see 2021-006)
Criteria: Section 200.214 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. This guidance requires a non-federal entity to establish policies and procedures for verifying the status of contractors and vendors whenever the value of a contract or cumulative transactions is expected to equal or exceed $25,000 to protect the federal government from fraud, waste and abuse.
Condition: During our detailed testing of suspension and debarment for the Crime Victim Assistance program, we noted that the Organization did not have a procedure in place to verify that its contractors and vendors receiving payments in excess of $25,000 were not suspended or debarred prior to doing business with them.
Effect of Condition: Two vendors charged to the Crime Victim Assistance program received payments in excess of the $25,000 testing threshold during the fiscal year. The Organization did not perform the necessary suspension or debarment testing prior to doing business with them. A subsequent vendor search on the federal System for Award Management (SAM.gov) website indicated that the vendors were eligible for participation in federal assistance programs or activities.
Cause of Condition: Entity personnel failed to verify the status of contractors and vendors prior to entering into business contracts or transactions.
Recommendation: The Organization should implement an internal control system that includes verifying vendors charged over $25,000 to federal grants are reviewed on the SAM.gov website.