Finding Text
Federal Agency: Department of Veterans Affairs
Federal Program Name: VA Homeless Providers Grant and Per Diem Program
Assistance Listing Number: 64.024
Federal Award Identification Number and Year: INNV143-1419-537-PD-21; INNV143-1620-537-TP-21; INNV143-1075-537-CM20; INNV143-2290-537-CM-22
Award Period: 10/1/20-9/30/21; 10/1/21-9/30/22; 10/1/20-9/30/23
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Other Matters
Criteria or specific requirement: When Inner Voice enters a covered transaction with an entity at a lower tier, Inner Voice must verify that the non-Federal entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: In testing the suspension and debarment requirement, it was noted not all certifications with vendors were obtained prior to executing the procurement contract.
Questioned costs: None.
Context: We noted two out of five procurement transactions tested, suspension and/or debarment certifications were not obtained prior to executing the transaction.
Cause: The Inner Voice was not aware of the need to verify non-Federal entities were not suspended or debarred prior to procurement.
Effect: By not obtaining proper suspension and debarment certifications, Inner Voice runs the risk of securing a contract with a vendor who is suspended or debarred.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend Inner Voice verify all procurement contracts are with vendors who are not suspended or debarred. This verification may be accomplished by:
1. Checking the System for Award Management (SAM) Exclusions
2. Collecting a certification form, or
3. Adding a clause or condition to the covered transaction with that entity
Views of responsible officials and planned corrective actions: Management agrees with the finding. Vendors who reached $20,000 in payments during the fiscal year will be reviewed in SAM for exclusions prior to procurement.