Finding Text
Federal Agency: US Department of Education
Federal Program Name: Education Stabilization Fund
Assistance Listing Number: 84.425F
Federal Award Identification Number and Year: P425F204449 2023
Award Period: July 1, 2022 to June 30, 2023
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction.
Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction.
Questioned costs: None
Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained.
Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction.
Effect: The College could enter a covered transaction with an entity that is suspended or disbarred.
Repeat Finding: No
Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.