Section III – Findings and Questioned Costs – Major Federal Programs
Federal Agency: U.S. Department of Agriculture
Federal Program Name: Extension Services at 1890 Colleges and the Education Stabilization Fund Assistance Listing Number: 10.512; 84.425
Federal Award Identification Number and Year: NI201444XXXXG008-0005; P425J200025 - 2024 Award Period: July 1, 2023 – June 30, 2024
Type of Finding:
Criteria or specific requirement: Per 2 CFR 180 and 2 CFR 200.213, nonfederal entities must ensure that vendors are not suspended or debarred from federal programs. Verification can be performed by checking the SAM.gov 'Exclusions' list, collecting a certification from the vendor, or including a clause in the contract requiring compliance.
Condition: Documentation supporting the University's suspension and debarment checks for sampled vendors was not maintained.
Questioned costs: None.
Context: During testing of Suspension and Debarment compliance, we noted that three out of three sampled procurement transactions tested for Program 10.512, as well as two out of two sampled transactions tested for Program 84.425, did not include documentation demonstrating that vendors were verified as not suspended or debarred prior to award.
Cause: The University did not maintain records of suspension and debarment checks for sampled transactions.
Effect: Without documented verification, there is an increased risk that federal funds could be expended with ineligible vendors, resulting in potential noncompliance with Uniform Guidance and exposure to questioned costs.
Recommendation: We recommend the University implement and enforce procedures to verify vendor status through SAM.gov or other acceptable methods prior to award, retain documentation of the verification in procurement files, and train staff on suspension and debarment requirements under Uniform Guidance.
Views of responsible officials: There is no disagreement with the audit finding.