Finding Text
Finding 2022-006: Suspension and Debarment and U.S. Government Regulations on Terrorism
Information on the Federal Programs: Assistance Listing Number 98.001
Criteria: CFR 200.213 states that 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. Additionally, as outlined in each Department of State award, recipients of U.S. Government funds must adhere to the United States Government’s requirements on screening all potential vendors, suppliers, sub-contractors/grantees and employees against the United States Department of State’s Terrorism watch list. The screening of all potential vendors, suppliers, subcontractors/ grantees and employees must be documented in writing.
Condition: Astraea did not provide documentation to support its screenings for its potential and current vendors, suppliers, contractors, employees, etc. that were paid with Federal funds.
Cause: Astraea did not have a procedure in place to ensure all required screenings are performed and documentation to support the screening is maintained.
Context: During our audit, we inquired of evidence of such a process, and Astraea was unable to provide support with respect to this area. It should be noted, that Astraea did perform and document the required screenings in January 2023 (in response to the finding issued during the fiscal year 2021 audit finding).
Effect: Astraea could make payments to an entity or individual that has been debarred or suspended by the US Government; such costs would be disallowed, and Astraea could face consequences for lack of compliance.
Questioned Costs: None noted.
Identification as a Repeat Finding: Yes - Finding 2021-007.
Recommendation: We recommend Astraea develop a policy of how screenings will be performed and how documentation will be maintained in order to demonstrate compliance with government regulations. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.