Audit Reports

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DOT’s Suspension and Debarment Program Continues To Have Insufficient Controls

Project ID: 

As a steward of billions in taxpayer dollars, the Department of Transportation (DOT) must adhere to Federal suspension and debarment (S&D) regulations to prevent federally funded contract or grant awards to irresponsible parties. Federal S&D regulations require the Department to make timely S&D decisions and to accurately and timely report its decisions to the governmentwide S&D System for Award Management (SAM). In January 2010, we reported significant delays in DOT’s S&D decision making and reporting and a lack of internal controls to adequately safeguard against awards to excluded parties. Given these deficiencies, we conducted a follow-up review of DOT’s S&D program.

While the Department has taken some actions to address issues identified in our 2010 audit, many of the Department’s decisions to suspend, debar, or take other S&D actions continue to be untimely. Specifically, Operating Administrations’ S&D decisions for at least 87 of the 218 S&D parties (40 percent) we reviewed were made after the 45‑day requirement. We also identified significant data errors in the DOT S&D system, which undermine the system’s effectiveness as a management tool. In addition, the Department continues to provide untimely and inaccurate reporting of its S&D actions to SAM. Our review determined that a significant number of the 144 excluded parties we reviewed were not reported within required timeframes. Additionally, because the Department did not adequately reconcile and validate the data in the DOT S&D system, we identified seven parties that were listed as suspended or debarred in the DOT S&D system but were not included in SAM. Failure to report excluded parties puts the Federal Government at risk of doing business with prohibited parties found to be unethical or irresponsible.

DOT’s Office of the Senior Procurement Executive either concurred or partially concurred with all seven recommendations we made to strengthen DOT’s S&D program. 




Closed on 02.11.2016
No. 1 to OST

Implement a detailed process for OSPE staff to regularly evaluate Operating Administrations' compliance with departmental and Federal timeframes for (a) initiating an S&D action (within the DOT S&D Order 45-day requirement) and (B)reporting to SAM (3 days for procurement actions; 5 days for non-procurement actions). This process should include follow-up actions to correct instances of noncompliance.

Closed on 06.28.2017
No. 2 to OST

Require all Operating Administrations to establish or update their S&D procedures to implement Federal S&D requirements and the DOT S&D Order, including a) requiring recipients to report exclusions and b) strongly recommending that recipients of non-procurement agreements check SAM before awarding third-party assistance agreements or contracts.

Closed on 04.18.2016
No. 3 to OST

Implement detailed procedures for regularly verifying the accuracy and completeness of the data reported to the DOT S&D system—including, at a minimum, the key data fields needed for OSPE to assess the timeliness of decisions and reporting.

Closed on 06.23.2016
No. 4 to OST

Develop a data dictionary for the DOT S&D system that defines each data field and identifies which fields to populate. Make this data dictionary available to all relevant stakeholders and include it in DOT S&D system training.

Closed on 03.23.2016
No. 5 to OST

Revise the DOT S&D Order to reflect the transition to SAM—including revised Federal timeframes for entering data into SAM.

Closed on 04.18.2016
No. 6 to OST

Implement a detailed process for OSPE staff to regularly reconcile data in the DOT S&D system and SAM—including steps for identifying and correcting data discrepancies. Using this new process, complete a comprehensive reconciliation of data in the DOT S&D system and SAM, and correct any discrepancies.

Closed on 03.23.2016
No. 7 to OST

Conduct and document quarterly internal S&D meetings with all Operating Administrations and S&D stakeholders, as established in the DOT S&D Order.