Finding 8841 (2022-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-01-18

AI Summary

  • Core Issue: USTTI failed to screen vendors and contractors for suspension and debarment, risking Federal fund misuse.
  • Impacted Requirements: Compliance with 2 CFR §200.213, which mandates checks against debarred parties before engaging in Federal assistance.
  • Recommended Follow-Up: Develop a formal policy for screening vendors and contractors, ensuring checks are done before contracts or payments are finalized.

Finding Text

Finding 2022-004: Suspension and Debarment Criteria: Under 2 CFR §200.213, Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict 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. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over Suspension and Debarment, we determined that USTTI did not perform screenings on potential or current vendors, suppliers or contractors that were paid with Federal funds. Cause: USTTI does not have a formal internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment. Effect: Failure to screen potential and current vendors, suppliers, contractors and employees increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None. Context: We noted that vendors, suppliers etc. selected for testing did not have a formally documented Suspension and Debarment check conducted prior to engagement. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. This policy should include a threshold for when vendors, suppliers, contractors and employees should be screened. All screenings should be conducted prior to signing a contract or issuing payment. We recommend that USTTI notify all employees of this policy and ensure that it is enforced during the upcoming fiscal year.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: USTTI management will develop and implement a formal policy on suspension and debarment. The policy will include a threshold for when vendors, suppliers, contractors and employees should be screened and no contract will be signed or payment issued until all screenings have been conducted. All USTTI employees will be notified of this policy.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 8839 2022-002
    Significant Deficiency
  • 8840 2022-003
    Significant Deficiency
  • 8842 2022-005
    Significant Deficiency
  • 8843 2022-002
    Significant Deficiency
  • 8844 2022-003
    Significant Deficiency
  • 8845 2022-004
    Significant Deficiency
  • 8846 2022-005
    Significant Deficiency
  • 8847 2022-002
    Significant Deficiency
  • 8848 2022-003
    Significant Deficiency
  • 8849 2022-004
    Significant Deficiency
  • 8850 2022-005
    Significant Deficiency
  • 585281 2022-002
    Significant Deficiency
  • 585282 2022-003
    Significant Deficiency
  • 585283 2022-004
    Significant Deficiency
  • 585284 2022-005
    Significant Deficiency
  • 585285 2022-002
    Significant Deficiency
  • 585286 2022-003
    Significant Deficiency
  • 585287 2022-004
    Significant Deficiency
  • 585288 2022-005
    Significant Deficiency
  • 585289 2022-002
    Significant Deficiency
  • 585290 2022-003
    Significant Deficiency
  • 585291 2022-004
    Significant Deficiency
  • 585292 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.322 Economic Statecraft $745,418
19.700 General Department of State Assistance $472,297
11.553 Special Projects $289,000