Finding Text
Finding 2023-003: Suspension and Debarment
Federal Programs: ALN 14.235
Criteria or Specific Requirement: Recipients of U.S. Government funds must adhere to specific
requirements on screening all potential vendors, suppliers and sub-contractors/grantees to ensure
the organization is not conducting business with excluded parties (as defined by the U.S.
Government); the screening must be documented in writing.
Condition: During the fiscal year, NEW did not consistently perform the screening process for its
potential and current vendors, suppliers, contractors, subrecipients, employees, fellows, etc. that
were paid with Federal funds.
Cause: NEW has a formal policy in place with regard to suspension and debarment screenings, but
did not adhere to its policy and retain documentation of screenings, during the fiscal year.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors,
subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: Indeterminable
Context: Payments were made during the fiscal year without performing the proper screening
process. Our audit work in this area consisted of internal control testwork over a random sample of
expenditures, as well as substantive testwork over transactions above a defined threshold from
select expense accounts that were charged to the Federal program. We consider our samples to be
representative of the respective populations, and thus, are statistically valid samples. The issue is
deemed to be systemic.
Identification as a Repeat Finding, if Applicable: 2020-001, 2021-001, 2022-003
Recommendation: We recommend NEW revisit its current policy and ensure that all types of parties
(as noted above) are included, and educate its employees on the procedures necessary to ensure full
compliance with this requirement. We also recommend NEW document each of these screenings
and retain them in the respective files, which should be completed prior to engaging in relationships
with these parties. For ongoing relationships, NEW should consider performing screenings on an
annual basis (and document them) to ensure continuous compliance in the event the suspension and
debarment status of any of these parties changes. Lastly, we recommend NEW perform
retrospective screenings on these parties it made payments to during the fiscal year.