RIVER NETWORK

Finding 2024-001

Procurement, Suspension and Debarment 15.954 National Park Service Conservation, Protection, Outreach, and Education and 10.727 Inflation Reduction Act Urban and Community Forestry Program.

Criteria: A recipient of federal awards is required to ensure that contractors and subrecipients are checked against the debarment list and ensure there are controls in place over procurement per 2 CFR section 180.220.

Condition and Context: The Organization did not check a contractor and a subrecipient against the debarment list. The Organization did not have a formally documented or enacted process in place to ensure all procurement requirements were completed accurately and timely. And there was also no underlying supporting documentation showing that subrecipients and contractors were checked against the debarment list.

Cause: The Organization was not aware that contractors and subrecipients needed to be checked against the debarment list.

Effect or Potential Effect: Without sufficient documentation, the Organization may have contracted with an Organization that was debarred. The related review of debarment was not documented. Without sufficient documentation and monitoring controls, the Organization may not be able to detect an error in procurement timely.

Recommendation: We recommend the Organization update their policies and procedures manual to ensure testing contractors and subrecipients to the debarment list when expenses reach federal limits.

Responsible Official’s Response: Management agrees with the recommendation to establish and follow a documented internal control process over the review of procurement. Staff will work with management to ensure that subrecipients and contractors with expenses over federal limits will be tested against the debarment list. Additionally, staff members working in areas concerning this process will be trained to ensure process adherence.