Finding Text
Finding 2023-003: Non-Compliance with Suspension and Debarment
Information on the Federal Program: 93.368
Criteria: 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: We noted that while the Foundation does conduct screenings on all vendors, suppliers
and consultants, the date that the screening is conducted is not documented. As such, we are
unable to determine if the screening was conducted prior to payment or signing of the contract.
Cause: The Foundation does not require that the date the screening is conducted be documented.
Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or
contract signing 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 noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged
to the Federal awards. The report in which samples were selected was generated directly from the
Foundation's general ledger (accounting system). We consider our sample to be representative of
the population. The condition appeared to be systematic in nature.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation revise their policy regarding suspension
and debarment to require that all screenings are accompanied by the documented date in which
they were conducted.