FAC Explorer

Finding 944395 (2023-001)

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Requirement
I
Questioned Costs
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Year
2023
Accepted
2024-02-14
Audit: 290437
Organization: Vanderbilt University (TN)
Auditor: Pwc LLP

AI Summary

  • Core Issue: The University failed to provide evidence of suspension and debarment checks for 3 out of 25 vendors during the 2023 award year.
  • Impacted Requirements: Compliance with 2 CFR section 180.995, which mandates verification that vendors are not suspended or debarred before transactions.
  • Recommended Follow-Up: Reinforce the importance of documentation for suspension and debarment checks and consider implementing a routine review control for all vendors.

Finding Text

Section III – Federal Award Findings and Questioned Costs /Finding 2023-001: Suspension and Debarment Check/ Federal Agency: Various /Program: Research and Development Cluster /Assistance Listing #: Various /Award #:Various/Award Year: 2023/ Criteria: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the 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. Questioned Costs: None. Condition: During the 2023 award year, for three out of twenty-five vendors tested in our sample of suspension and debarment checks, there was no evidence provided that the checks were performed. The University subsequently verified these vendors are not suspended or debarred. Cause: The University’s internal controls include uploading all vendors into the GIACT online system, which tracks suspension and debarment. Upon completion of this upload, the GIACT system tracks suspension and debarment and notifies the University if there is a suspended or debarred name match (full/partial) on a vendor. For the three vendors noted above, management could not provide evidence that the vendors had been loaded into GIACT or that any other type of review or check for suspension and debarment had been performed. Effect: The University did not maintain evidence of its review for suspension and debarment for certain vendors. Recommendation: We recommend the University reiterate to control owners the importance of ensuring suspension and debarment checks is performed and that adequate documentation of the checks are maintained pursuant to its internal controls and policies. Additionally, a review control to ensure suspension and debarment checks are performed for all vendors on a routine basis should be considered. Views of Responsible Officials/Management Response: See Management’s view and corrective action plan included at the end of this report.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $107.72M
97.067 Homeland Security Grant Program $12.13M
84.063 Federal Pell Grant Program $6.95M
81.049 Office of Science Financial Assistance Program $5.29M
84.038 Federal Perkins Loan Program $4.96M
98.RD Agency for International Development $2.82M
84.027 Special Education_grants to States $2.61M
93.264 Nurse Faculty Loan Program (nflp) $2.00M
84.033 Federal Work-Study Program $1.61M
84.007 Federal Supplemental Educational Opportunity Grants $1.34M
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $791,714
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $745,236
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $673,180
93.925 Scholarships for Health Professions Students From Disadvantaged Backgrounds $649,111
66.RD Environmental Protection Agency $591,681
12.300 Basic and Applied Scientific Research $508,610
93.247 Advanced Nursing Education Grant Program $467,131
93.879 Medical Library Assistance $434,477
81.086 Conservation Research and Development $425,446
93.870 Maternal, Infant and Early Childhood Home Visiting Grant Program $418,300
19.600 Bureau of Near Eastern Affairs $393,128
93.866 Aging Research $388,178
93.600 Head Start $344,948
93.172 Human Genome Research $325,310
93.398 Cancer Research Manpower $316,199
43.002 Aeronautics $314,324
93.364 Nursing Student Loans $302,500
43.009 Cross Agency Support $250,056
19.010 Academic Exchange Programs - Hubert H. Humphrey Fellowship Program $249,052
81.135 Advanced Research Projects Agency - Energy $242,367
93.173 Research Related to Deafness and Communication Disorders $238,639
20.820 Maritime Studies and Innovations $233,259
93.394 Cancer Detection and Diagnosis Research $229,664
93.590 Community-Based Child Abuse Prevention Grants $224,723
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $208,515
93.395 Cancer Treatment Research $201,096
93.516 Public Health Training Centers Program $182,648
84.RD Department of Education $178,947
93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service $163,026
93.213 Research and Training in Complementary and Integrative Health $162,444
47.041 Engineering Grants $133,976
84.326 Special Education_technical Assistance and Dissemination to Improve Services and Results for Children with Disabilities $122,513
45.169 Promotion of the Humanities_office of Digital Humanities $121,111
11.609 Measurement and Engineering Research and Standards $120,288
12.RD Department of Defense $114,718
93.969 Pphf Geriatric Education Centers $105,613
47.076 Education and Human Resources $99,763
93.350 National Center for Advancing Translational Sciences $88,705
93.226 Research on Healthcare Costs, Quality and Outcomes $87,446
93.865 Child Health and Human Development Extramural Research $84,668
12.431 Basic Scientific Research $81,992
20.530 Public Transportation Innovation $80,079
84.015 National Resource Centers Program for Foreign Language and Area Studies Or Foreign Language and International Studies Program and Foreign Language and Area Studies Fellowship Program $77,137
12.225 Commercial Technologies for Maintenance Activities Program $77,014
47.084 National Science Foundation Technology Innovation and Partnerships $76,786
93.351 Research Infrastructure Programs $75,575
47.070 Computer and Information Science and Engineering $64,938
47.079 Office of International Science and Engineering $63,131
81.121 Nuclear Energy Research, Development and Demonstration $61,813
15.926 American Battlefield Protection $60,538
93.959 Block Grants for Prevention and Treatment of Substance Abuse $59,926
93.884 Grants for Primary Care Training and Enhancement $58,254
43.012 Space Technology $58,165
15.509 Title Ii, Colorado River Basin Salinity Control $52,992
93.113 Environmental Health $51,072
43.003 Exploration $50,193
93.630 Developmental Disabilities Basic Support and Advocacy Grants $48,035
93.242 Mental Health Research Grants $43,998
93.564 Child Support Enforcement Research $42,927
93.361 Nursing Research $37,671
64.RD Interagency Personnel Agreement $32,801
12.800 Air Force Defense Research Sciences Program $32,562
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $31,579
93.283 Centers for Disease Control and Prevention_investigations and Technical Assistance $28,163
93.943 Epidemiologic Research Studies of Acquired Immunodeficiency Syndrome (aids) and Human Immunodeficiency Virus (hiv) Infection in Selected Population Groups $28,017
93.547 National Health Service Corps $27,690
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $24,992
93.310 Trans-Nih Research Support $24,299
66.509 Science to Achieve Results (star) Research Program $22,744
47.083 Office of Integrative Activities $22,306
12.910 Research and Technology Development $21,956
93.837 Cardiovascular Diseases Research $20,318
84.324 Research in Special Education $19,460
81.089 Fossil Energy Research and Development $18,271
93.110 Maternal and Child Health Federal Consolidated Programs $17,697
10.001 Agricultural Research_basic and Applied Research $17,362
93.145 Hiv-Related Training and Technical Assistance $17,163
47.050 Geosciences $16,838
93.393 Cancer Cause and Prevention Research $16,310
20.724 Pipeline Safety Research Competitive Academic Agreement Program (caap) $16,243
93.397 Cancer Centers Support Grants $15,398
84.206 Javits Gifted and Talented Students Education $14,481
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $12,903
84.022 Overseas Programs - Doctoral Dissertation Research Abroad $12,842
20.616 National Priority Safety Programs $11,421
93.867 Vision Research $10,289
93.273 Alcohol Research Programs $10,085
14.218 Community Development Block Grants/entitlement Grants $9,495
84.305 Education Research, Development and Dissemination $8,970
45.024 Promotion of the Arts_grants to Organizations and Individuals $8,464
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $7,942
20.205 Highway Planning and Construction $7,906
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $6,601
45.160 Promotion of the Humanities_fellowships and Stipends $6,251
93.136 Injury Prevention and Control Research and State and Community Based Programs $5,787
43.001 Science $5,719
12.901 Mathematical Sciences Grants Program $5,715
19.040 Public Diplomacy Programs $5,138
47.049 Mathematical and Physical Sciences $4,727
20.RD Department of Transportation $4,359
12.351 Scientific Research - Combating Weapons of Mass Destruction $4,337
81.RD Department of Energy $4,062
20.215 Highway Training and Education $3,264
47.RD National Science Foundation $2,700
12.420 Military Medical Research and Development $2,325
93.233 National Center on Sleep Disorders Research $2,262
43.008 Education $1,807
93.396 Cancer Biology Research $1,708
97.RD Department of Homeland Security $1,629
81.087 Renewable Energy Research and Development $993
93.855 Allergy and Infectious Diseases Research $706
84.411 Investing in Innovation (i3) Fund $691
47.075 Social, Behavioral, and Economic Sciences $353
45.312 National Leadership Grants $303
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $185
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $89
93.307 Minority Health and Health Disparities Research $45
98.001 Usaid Foreign Assistance for Programs Overseas $36
47.074 Biological Sciences $14
93.859 Biomedical Research and Research Training $5
10.310 Agriculture and Food Research Initiative (afri) $-24
93.RD Department of Health and Human Services $-29
93.279 Drug Abuse and Addiction Research Programs $-68
93.838 Lung Diseases Research $-88
93.839 Blood Diseases and Resources Research $-102
43.RD National Aeronautics and Space Administration $-221
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $-485
93.732 Mental and Behavioral Health Education and Training Grants $-1,140
12.750 Uniformed Services University Medical Research Projects $-1,495
93.121 Oral Diseases and Disorders Research $-4,520
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $-9,590
84.181 Special Education-Grants for Infants and Families $-10,232
10.025 Plant and Animal Disease, Pest Control, and Animal Care $-20,766
84.407 Transition Programs for Students with Intellectual Disabilities Into Higher Education $-98,714