Finding Text
Type of Finding: Material Weakness in Internal Control over Compliance and Significant Deficiency over Compliance
Condition: None of the five samples selected for testing had appropriate suspension and debarment checks prior to entering into the subawards.
Criteria or specific requirement: § 200.214 Suspension and debarment.
Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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.
Effect: Without proper controls the Organization could enter award subrecipients with entities that are suspended or debarred.
Cause: The Organization was unaware of the requirement to perform suspension and debarment checks on subrecipients.
Recommendation: The Organization should Implement policies and procedures for performing suspension and debarment checks for all covered transactions, including subrecipients.
Repeat Finding?: No
Questioned Costs: None