OPEN GOVERNMENT PARTNERSHIP SECRETARIAT

Finding 2022-001: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 98.001 Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Under 2 CFR ?200.213, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations 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. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: It is our understanding that the Organization only includes self-certification paragraphs in all vendor contracts. The Organization did not, however, in any instance, perform screenings on its potential or current vendors, suppliers, contractors or non-domestic employees that were paid with Federal funds. Cause: The Organization does not have a formal internal policy with respect to screening vendors, suppliers, contractors or non-domestic employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors, and non-domestic employees increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Organization's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that management develop and implement a formal policy regarding when suspension and debarment checks are conducted, and when a self-certification is sufficient. This policy should include a threshold, generally $25,000, for when vendors, suppliers, contractors or non-domestic employees should be screened. All screenings should be conducted prior to signing a contract or issuing payment.