Finding Text
2022-001: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425F Award Period: July 01, 2021 - June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards include elements that should be included in a written procurement policy. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215?. Condition: During testing, it was noted there was no documentation to ensure the vendors were not suspended or debarred. In addition, there was no documentation of a second review to ensure the vendors were not suspended or debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University?s control system to document the prevention of contracting with a suspended and barred vendor was not in place. Effect: The University could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: Yes, see 2021-001 Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Views of Responsible Officials: Management agrees with finding.