Finding 972914 (2023-002)

Internal Control over Compliance with Suspension and Debarment Requirements Federal Agency: U.S. Department of State, Bureau of Educational and Cultural Affairs Assistance Listing Numbers: 19.415 Federal Program Names: Professional and Cultural Exchange Programs – Citizen Exchanges Pass-through Entity: American Councils for International Education Pass-through Award Number: S-ECAGD-22-CA-0039 Criteria: Under 2 CFR 200.318, the non-federal entity must have and use documented procurement procedures, consistent with laws and regulations, to ensure the entity does not enter into contracts for covered transactions over $25,000. Condition: The excluded parties search or other verification of suspension and debarment status was not documented for certain covered transactions during the year ended June 30, 2023. Cause: During the year ended June 30, 2023, the Organization experienced turnover in its program and accounting departments, resulting in certain internal controls over compliance being missed. Effect: Inadequate controls over suspension and debarment requirements could result in the Organization expending federal award funds on contracts or other covered transactions with entities that have been suspended or debarred. Recommendation: We recommend that management develops and implements specific internal controls to verify suspension and debarment status for all covered transactions with potential contractors and vendors. Views of Responsible Officials: There is no disagreement with the finding.