Rocky Mountain Institute

Finding: Suspension and Debarment Research and Development Cluster Department of Transportation Assistance Listing Number 20.942 Thriving Communities Program Capacity Builders Cooperative Agreements Award Number: 69A6212350002 Award Year 2025 Criteria or Specific Requirement: Per 2 CFR 180, all non-federal entities are prohibited from contracting with or making sub-awards under covered transactions with parties that are suspended or debarred or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition.Documentation to support compliance with the above requirement was not available in six instances in which the Organization did not check the suspension and debarment via the excluded parties listing (EPLS) prior to entering the contract. Documentation was provided to support that checks via the EPLS system were completed on the six contractors/vendors selected prior to any payments being made to those six contractors/vendors. Questioned Costs: None. Context: We tested a sample of 6 of 36 vendors to evaluate compliance with the applicable procurement requirements, including the review of the excluded party list, and noted the above issue related to the Programs and Thriving Communities Program. A non-statistical sampling methodology was used to select the sample. Effect: By not verifying vendors against the excluded party list, the Organization risks contracting with and making payments to a contractor/vendor that has been suspended or debarred in a violation of federal regulations. Cause: The Organization did not have controls in place to perform the suspension and debarment check prior to entering into a covered transaction Recommendation: We recommend that the Organization update its current policies and procedures to ensure that the "Excluded Parties List" be reviewed prior to awarding a provider contract, purchase order or contract extension, and on an annual basis thereafter. Performance of such reviews should be documented by including supporting documentation in the contract file. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. See separate report for planned corrective actions.

Finding: Suspension and Debarment Research and Development Cluster Department of State Assistance Listing Number 19.017 Environmental and Scientific Partnership and Programs Award Number: SAQMIP23GR0057 Award Year 2024

Criteria or Specific Requirement: Per 2 CFR 180, all non-federal entities are prohibited from contracting with or making sub-awards under covered transactions with parties that are suspended or debarred or otherwise excluded from or ineligible for participation in federal assistance programs or activities.

Condition: Documentation to support compliance with the above requirement was not available in one instance in which the Organization did not check the suspension and debarment via the excluded parties listing (EPLS) prior to entering into the contract.

Questioned Costs: None.

Context: We tested a sample of 3 of 26 vendors to evaluate compliance with the applicable procurement requirements, including the review of the excluded party list, and noted the above issue related to the Climate Finance Access Network. A non-statistical sampling methodology was used to select the sample.

Effect: By not verifying vendors against the excluded party list, the Organization risks contracting with and making payments to a contractor/vendor that has been suspended or debarred in a violation of federal regulations.

Cause: The Organization did not have controls in place to perform the suspension and debarment check prior to entering into a covered transaction.

Recommendation: We recommend that the Organization update its current policies and procedures to ensure that the "Excluded Parties List" be reviewed prior to awarding a provider contract, purchase order or contract extension, and on an annual basis thereafter. Performance of such reviews should be documented by including supporting documentation in the contract file.