Finding Text
nformation on Federal Program: Federal Grantor: United States Department of Education Assistance Listing No.: 84.116 Major Program: Fund for the Improvement of Postsecondary EducationAward Period: January 1, 2021- December 31, 2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 states of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Strada Collaborative, LLC did not have suitably designed internal controls in place over the major program; Fund for the Improvement of Postsecondary Education, related to procurement, suspension and debarment.Cause: Strada Collaborative, LLC did not effectively design internal controls to require validation that all vendors appropriately have a signed contract with a specific addendum related to suspension and debarment prior to payment.Effect or potential effect: Strada Collaborative, LLC enters into a contract with a vendor that has been suspended or debarred resulting in the Company being unable to receive any new awards from the Federal Government or conduct business with the Federal Government.Questioned costs: None Context: We selected a sample of 6 subcontractors (vendors) to test the compliance requirements for procurement, suspension and debarment for the year ended December 31, 2023. We noted one vendor that the Company did not obtain confirmation of suspension and debarment. As this was the only exception, the maximum exposure is $29k.