Finding Text
Federal Agency: Department of Education
Federal Program Title: Research and Development
CFDA Number: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters)
Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and
180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying
that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or
otherwise excluded.
Condition: The University could not produce documentation to show that they performed suspension
and debarment verification procedures prior to contracting with the vendors.
Questioned costs: None.
Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate
that verification procedures were performed prior to contracting with the vendors. However, the
University was able to subsequently verify that the vendors were not suspended or debarred.
Cause: While the University has suspension and debarment procedures in place, they did not
document that the check had been completed for these 2 vendors.
Effect: If verification procedures are not performed in a timely manner, the University could enter into
contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed
costs.
Repeat Finding: No.
Recommendation: We recommend the University document suspension and debarment procedures
going forward for any aggregate disbursements with vendors greater than $25,000.
Views of responsible officials: There is no disagreement with the audit finding. Management has
addressed their corrective action plan in a separately issued letter.