Finding 950929 (2023-001)

Information on the Federal Program: Federal Agency: United States Department of Treasury Program Names: Coronavirus State and Local Fiscal Recovery Funds AL: 21.027 Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted CCSNH did not consistently review the SAM for vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that none of the vendors and employees selected in our testing that were charged to the grant were included in the SAM listing. Although we did note CCSNH has a process to review grant-funded employees upon hire and on a monthly basis to the SAM and to grant-funded vendors prior to payment, this review did not occur for the vendors and employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: CCSNH is aware of the requirement to verify vendors and employees against the SAM. Given the nature and timing of when these grant funds were awarded, the employees and vendors were not hired specifically to work on this grant and therefore the reviews were not performed. Since this process was not performed on employees and vendors, there was a risk that employees and vendors who may be included on the SAM were included in the expenditures for this federal program. Identification as a Repeat Finding, if applicable: N/A Recommendation: We recommend CCSNH implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. We also recommend CCSNH provide additional training to all individual at the System and the individual college involved in the accounts payable, procurement and payroll processes on the importance of the SAM reviews and the existing System policies and procedures regarding suspension and debarment. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan on page 84. Responsible party: John Harrington, Controller, (603) 230-3505