Finding Text
Finding 2023-001: Significant Deficiency – Lack of Documentation of Verification of Vendors
Federal grantor: Department of Justice
Condition: The Association contracts with a vendor and, although they did verify the vendor was not on the list of
vendors suspended or debarred from federal contracting before contracting with the vendor, they did not document
this verification.
Criteria: Entities must comply with 2 CFR Part 1326 that prohibits entities that have been debarred, suspended or
voluntarily excluded from participating in Federal procurement.
Cause: The grant agreement contains a requirement to verify or receive vendor certification that they are not
debarred suspended, ineligible or voluntarily excluded from Federal procurements. Although this procedure was
followed based on our discussion with Association staff, documentation was not retained proving that the
verification was performed prior to entering into the contract.
Effect: We are not able to determine if the Association verified the vendor prior to contracting.
Recommendation: We recommend the Association ensure that documentation of compliance with grant
requirements is retained for the Association’s records. Management’s Response: Management response to the finding is discussed in the Correction Action Plan.