Finding 971057 (2023-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-04-25
Audit: 304505
Organization: Seattle Aquarium Society (WA)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: The Aquarium failed to verify vendor suspension and debarment before signing contracts, which is a significant internal control deficiency.
  • Impacted Requirements: Compliance with federal regulations (2 CFR section 180) that prohibit contracting with suspended or debarred parties.
  • Recommended Follow-Up: Update procurement policies to ensure verification of vendor status is completed prior to contract execution for federal awards.

Finding Text

Finding 2023-002 Significant deficiency in internal control over compliance with suspension and debarment requirements Federal Agency: Department of Housing and Urban Development Assistance Listing Number: 14.251 Assistance Listing Name: Community Project Funding Award Number: B-23-CP-WA-1530 Criteria Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred and must verify that such parties are not suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The source of requirements for suspension and debarment are in 2 CFR 180. Condition and Context During our testing of the suspension and debarment compliance requirement, we noted that the Aquarium had not performed the required verification at the time of entering into applicable vendor contracts. We tested a sample of two vendors and the Aquarium had not performed the required verification on these vendors. However, at the time of our audit testing, the Aquarium did check the System for Award Management Exclusions and verified that neither vendor was suspended or debarred. Cause The Aquarium’s system of internal control did not require performance of the required verification of suspension and debarment for vendors before entering into vendor contracts. Effect The effect of this control deficiency is the Aquarium is at risk of entering into a vendor contract before the Aquarium has verified the vendor is not suspended or debarred. Questioned Costs None. Repeat Finding This is not a repeat finding.Recommendation We recommend management update its procurement policies and procedures to perform the required verification for suspension and debarment before entering into vendor contracts that will be charged to federal awards. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 394614 2023-001
    Material Weakness
  • 394615 2023-002
    Significant Deficiency
  • 971056 2023-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.251 Community Project Funding $750,000
66.123 Puget Sound Action Agenda: Technical Investigations and Implementation Assistance Program $51,687
11.454 Unallied Management Projects $22,243