Finding Text
Finding 2023-002: Non-Compliance with Suspension and Debarment
Information on the Federal Programs: 19.517; 19.519; 98.001
Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement 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: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees.
Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None noted.
Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample.
Identification as a Repeat Finding: 2022-001
Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.