{"what_this_is":"The steps as the government wrote them, grouped by procedure family, with the auditor's test cited and the steps where a dated receipt is the record.","families":{"sd_award":{"title":"Suspension and debarment check for federal awards (2 CFR 180 / 200)","steps":[{"n":1,"step":"Identify each covered transaction: a procurement contract expected to equal or exceed $25,000, any subaward, and any contract the award terms designate.","who":"recipient or pass-through entity","when":"before entering the transaction","record":"the procurement or subaward file","cite":"2 CFR 180.220(b); 2 CFR 200.214","receipt_step":false},{"n":2,"step":"Before entering it, do one of three things: (a) check SAM.gov Exclusions for the party, (b) collect a certification from the party, or (c) add a clause to the transaction.","who":"recipient","when":"before award","record":"the dated SAM exclusions read under the party's name and UEI — option (a)","cite":"2 CFR 180.300","receipt_step":true},{"n":3,"step":"Keep the read with the procurement history for that transaction.","who":"recipient","when":"at award","record":"dated, hashed receipt filed with the procurement record","cite":"2 CFR 200.318(i); Retain 3 years from the date the final expenditure report is submitted (2 CFR 200.334).","receipt_step":true},{"n":4,"step":"Pass the requirement down: the subaward or contract carries the 2 CFR 180 terms so the lower tier does the same.","who":"pass-through entity","when":"at subaward","record":"subaward terms","cite":"2 CFR 180.330; 2 CFR 200.332(a)","receipt_step":false},{"n":5,"step":"Where the program conditions a payment on the payee's eligibility, read the payee's name before disbursing and file it with the invoice.","who":"recipient (accounts payable)","when":"before each covered disbursement","record":"payment-time read on the payee's printed name","cite":"24 CFR 570.506 (CDBG records); 2 CFR 200.403","receipt_step":true}],"auditor_test":[{"test":"Select a sample of procurements at or above $25,000 and of subawards; determine whether, before entering each, the entity checked SAM Exclusions, collected a certification, or included a clause — and whether the file shows it.","cite":"OMB Compliance Supplement (2 CFR 200 App. XI), Part 3, Section I — Procurement and Suspension and Debarment, audit objectives and suggested audit procedures"},{"test":"Finding written when the check cannot be evidenced: 'documentation of verification through SAM.gov or equivalent methods was not available' (Hamilton Health Center 2025-003, FAC report 2025-03-GSAFAC-0000391916).","cite":"the auditor's words as filed at fac.gov"}],"forms":["two-cfr-180-300","sf-424b","hud-2992","ad-1048","epa-5700-49","fta-certs"]},"sd_far":{"title":"Suspension and debarment under the FAR (offeror representation; subcontract check)","steps":[{"n":1,"step":"The offeror keeps its representations current in SAM, including 52.209-5 (responsibility matters) and 52.204-26 (covered telecommunications).","who":"offeror","when":"annually and at each offer","record":"SAM Reps & Certs as filed","cite":"FAR 52.204-8; FAR 52.209-5; FAR 52.204-26","receipt_step":true},{"n":2,"step":"The contracting officer reviews SAM Exclusions for the apparent successful offeror before award.","who":"contracting officer","when":"immediately before award","record":"contract file","cite":"FAR 9.405(d)(1), (d)(4)","receipt_step":false},{"n":3,"step":"Before entering any subcontract exceeding $35,000 (other than COTS), the contractor reviews SAM Exclusions for the subcontractor.","who":"prime contractor","when":"before each subcontract","record":"the dated SAM exclusions read under the subcontractor's name","cite":"FAR 52.209-6(c)","receipt_step":true},{"n":4,"step":"If a proposed subcontractor is excluded, give the contracting officer written notice within 10 days with the required particulars.","who":"prime contractor","when":"within 10 days","record":"notice letter","cite":"FAR 52.209-6(d)","receipt_step":false},{"n":5,"step":"Keep the reads with the purchasing file.","who":"prime contractor","when":"through final payment","record":"receipts in the purchasing system","cite":"Retain 3 years after final payment (FAR 4.703(a)).","receipt_step":true}],"auditor_test":[{"test":"Contractor Purchasing System Review: the purchasing system must document that subcontractors are checked against SAM Exclusions before award.","cite":"DFARS 252.244-7001(c) system criteria; DCMA CPSR Guidebook"},{"test":"Contracting officer's pre-award file review for the SAM check and FAPIIS review.","cite":"FAR 9.405(d); FAR 9.104-6"}],"forms":["sam-reps-certs","far-52-209-6-subcontract","far-52-209-5-11"]},"subrecipient":{"title":"Subrecipient monitoring and single-audit follow-through (2 CFR 200.332, 200.501)","steps":[{"n":1,"step":"Decide, case by case, whether the party is a subrecipient or a contractor.","who":"pass-through entity","when":"before the agreement","record":"determination memo","cite":"2 CFR 200.331","receipt_step":false},{"n":2,"step":"Write the required terms into the subaward, including the federal award identification and the 2 CFR 180 flow-down.","who":"pass-through entity","when":"at subaward","record":"subaward agreement","cite":"2 CFR 200.332(a); 2 CFR 180.330","receipt_step":false},{"n":3,"step":"Verify that a subrecipient expected to expend $1,000,000 or more in federal awards in its fiscal year ($750,000 for fiscal years beginning before 1 Oct 2024) had the required audit, and that it was filed.","who":"pass-through entity","when":"each subrecipient fiscal year, within 9 months of its year end","record":"the dated FAC read: whether an SF-SAC is on file, the FY end, the finding references","cite":"2 CFR 200.332(f); 2 CFR 200.501(a); 2 CFR 200.512(a)","receipt_step":true},{"n":4,"step":"Issue a management decision on audit findings that pertain to the subaward within six months of FAC acceptance.","who":"pass-through entity","when":"within 6 months","record":"management decision letter","cite":"2 CFR 200.332(e); 2 CFR 200.521","receipt_step":false},{"n":5,"step":"Report each first-tier subaward of $30,000 or more, with the subrecipient's UEI, by the end of the month following the month of obligation.","who":"prime recipient","when":"monthly","record":"the USAspending subaward rows as published under the prime's UEI","cite":"2 CFR 170 Appendix A; FAR 52.204-10(d) for contracts","receipt_step":true}],"auditor_test":[{"test":"Determine whether the pass-through entity verified that subrecipients expending at or above the threshold met the audit requirement, and whether it issued management decisions and followed up.","cite":"OMB Compliance Supplement, Part 3, Section M — Subrecipient Monitoring"},{"test":"Finding written when the audit was not obtained: 'did not obtain the required audit report for the program subrecipient or perform any additional monitoring procedures' (County of Dauphin 2019-001, FAC 2019-12-CENSUS-0000166825).","cite":"the auditor's words as filed at fac.gov"}],"forms":["sf-sac","far-52-204-10","two-cfr-200-332"]},"davis_bacon":{"title":"Davis-Bacon and related acts on federally funded construction (29 CFR 5)","steps":[{"n":1,"step":"Put the wage determination and the labor standards clauses into the contract and every subcontract.","who":"contracting agency; prime for subs","when":"at solicitation and subcontract","record":"contract and subcontract","cite":"29 CFR 5.5(a); 29 CFR 5.6(a)(1)","receipt_step":false},{"n":2,"step":"Do not award to a person or firm on the WHD ineligible (debarred) list; check SAM Exclusions as well where federal funds flow.","who":"contracting agency; prime for subs","when":"before award and before each subcontract","record":"the dated SAM read; the WHD list is printed 'not read' with its official link because DOL refuses automated reads","cite":"29 CFR 5.12(a)(1); 2 CFR 180.300; FHWA-1273 §XI","receipt_step":true},{"n":3,"step":"Each contractor and subcontractor submits a weekly payroll with a signed Statement of Compliance.","who":"contractor and each subcontractor","when":"weekly, within 7 days of the pay date","record":"WH-347 or equivalent with Statement of Compliance","cite":"29 CFR 5.5(a)(3)(ii)","receipt_step":false},{"n":4,"step":"The agency reviews payrolls and conducts employee interviews.","who":"contracting agency","when":"during performance","record":"payroll review and interview records","cite":"29 CFR 5.6(a)(3)","receipt_step":false},{"n":5,"step":"Retain payrolls and basic records three years after completion.","who":"contractor","when":"3 years","record":"payroll records","cite":"29 CFR 5.5(a)(3)(i)","receipt_step":false}],"auditor_test":[{"test":"Federal-aid highway: the division office reviews the contracting agency's labor compliance, including that certified payrolls were obtained and reviewed and FHWA-1273 was physically incorporated.","cite":"23 CFR 635.117; 23 CFR 633.102"},{"test":"Single audit: where Part 4 of the program names wage-rate requirements, test that payrolls were obtained and reviewed.","cite":"OMB Compliance Supplement, Part 3, Section N — Special Tests and Provisions (Wage Rate Requirements), where applicable"}],"forms":["fhwa-1273","wh-347","sf-1413","hud-4010"]},"medicaid_screening":{"title":"Provider enrollment and exclusion screening (42 CFR 455; 42 CFR 1001.1901)","steps":[{"n":1,"step":"The provider files the state's enrollment application and discloses owners, managing employees, agents and criminal convictions.","who":"provider","when":"at enrollment and re-enrollment; within 35 days of a change","record":"state enrollment form","cite":"42 CFR 455.104; 455.105; 455.106","receipt_step":false},{"n":2,"step":"The state agency checks the provider and every disclosed person against the OIG LEIE and SAM Exclusions at enrollment and re-enrollment.","who":"state Medicaid agency","when":"at enrollment","record":"the dated LEIE + SAM read","cite":"42 CFR 455.436(b)","receipt_step":true},{"n":3,"step":"The state agency repeats the LEIE and SAM check monthly.","who":"state Medicaid agency","when":"monthly","record":"the monthly series of dated reads","cite":"42 CFR 455.436(c)(2)","receipt_step":true},{"n":4,"step":"No federal program payment for items or services furnished, ordered or prescribed by an excluded person; providers check their own staff and contractors.","who":"provider; managed care plan","when":"before hire or contract, then monthly","record":"the dated LEIE + SAM read per person or vendor","cite":"42 CFR 1001.1901(b); 42 CFR 438.610; OIG Special Advisory Bulletin on the Effect of Exclusion (2013)","receipt_step":true},{"n":5,"step":"Managed care plans screen and the state enrolls network providers; plans report excluded or terminated providers.","who":"managed care plan","when":"before network participation; ongoing","record":"roster of dated reads","cite":"42 CFR 438.608(b)–(c)","receipt_step":true}],"auditor_test":[{"test":"CMS and HHS-OIG review whether the state agency performed the database checks at enrollment and monthly and whether excluded providers were paid.","cite":"42 CFR 455.436; HHS-OIG audits of state Medicaid provider screening"},{"test":"Medicare Advantage / Part D: CMS program audits test the compliance program element for FDR exclusion screening before hire or contract and monthly.","cite":"42 CFR 422.503(b)(4)(vi)(F); CMS Program Audit Protocol — Compliance Program Effectiveness"}],"forms":["cms-855","medicaid-455","ma-fdr","mco-438-608","cms-855-ownership"]},"fapiis":{"title":"Responsibility information and SAM registration (FAR 52.209-7, 52.209-9, 52.204-7)","steps":[{"n":1,"step":"The offeror represents whether it holds federal contracts and grants totaling over $10 million and whether it has proceedings to disclose.","who":"offeror","when":"at each offer","record":"representation in SAM","cite":"FAR 52.209-7(b)","receipt_step":true},{"n":2,"step":"Enter the required proceedings information in FAPIIS through SAM.","who":"offeror / contractor","when":"at offer; updates semiannually","record":"FAPIIS proceedings section as filed","cite":"FAR 52.209-7(c); FAR 52.209-9(b)","receipt_step":true},{"n":3,"step":"Keep SAM registration active from offer through final payment.","who":"contractor","when":"continuously","record":"registration status and expiration date as registered","cite":"FAR 52.204-7(b)","receipt_step":true},{"n":4,"step":"The contracting officer reviews FAPIIS and SAM before award.","who":"contracting officer","when":"before award","record":"contract file","cite":"FAR 9.104-6; FAR 9.405(d)","receipt_step":false}],"auditor_test":[{"test":"Pre-award responsibility determination documented in the contract file, including the FAPIIS review.","cite":"FAR 9.104-6; FAR 9.105-2"}],"forms":["far-52-204-7","far-52-209-7"]},"small_business":{"title":"Small business size representation (FAR 52.219-1; 13 CFR 121)","steps":[{"n":1,"step":"Self-certify size and status for each NAICS code in SAM.","who":"offeror","when":"at registration and annually","record":"NAICS and size flags as registered","cite":"FAR 52.219-1(c); 13 CFR 121.404","receipt_step":true},{"n":2,"step":"Recertify within 30 days of a merger, acquisition or novation, and before the end of the fifth year of a long-term contract.","who":"contractor","when":"on the triggering event","record":"recertification in SAM","cite":"FAR 19.301-2(b); 13 CFR 121.404(g)","receipt_step":true},{"n":3,"step":"The contracting officer may accept the self-certification unless protested or there is reason to question it.","who":"contracting officer","when":"at award","record":"contract file","cite":"FAR 19.301-1(b)","receipt_step":false}],"auditor_test":[{"test":"Size is determined by SBA on protest or request, on average annual receipts or employees including affiliates — not by any registry read.","cite":"13 CFR 121.1001; 13 CFR 121.103"}],"forms":["far-52-219-1"]},"lobbying":{"title":"Lobbying certification and disclosure (31 U.S.C. 1352)","steps":[{"n":1,"step":"Certify at application that no federal appropriated funds have been or will be used to lobby in connection with the award.","who":"applicant","when":"at application and each tier","record":"certification (SF-424B assurance or FAR 52.203-11)","cite":"31 U.S.C. 1352; 2 CFR 200.450","receipt_step":false},{"n":2,"step":"File SF-LLL if non-federal funds were used to lobby in connection with the award.","who":"applicant / contractor","when":"at application; quarterly updates on change","record":"SF-LLL","cite":"31 U.S.C. 1352(b); FAR 52.203-12","receipt_step":false},{"n":3,"step":"Registrants and clients appear in the Senate Lobbying Disclosure Act database; foreign-principal agents in FARA.","who":"lobbying registrant","when":"quarterly","record":"LDA and FARA rows under the printed name, dated","cite":"2 U.S.C. 1603–1604; 22 U.S.C. 612","receipt_step":true}],"auditor_test":[{"test":"Lobbying costs are unallowable; test the certification and SF-LLL where applicable.","cite":"2 CFR 200.450; OMB Compliance Supplement, Part 3, Section B — Allowable Costs"}],"forms":["sf-lll"]},"hud_disclosure":{"title":"HUD applicant disclosure of other assistance and interested parties (24 CFR 4)","steps":[{"n":1,"step":"File HUD-2880 with the application when the threshold is met, listing other government assistance and interested parties.","who":"applicant","when":"at application","record":"HUD-2880","cite":"24 CFR 4.9; 42 U.S.C. 3545","receipt_step":false},{"n":2,"step":"Update the disclosure when the information changes by the stated amounts.","who":"recipient","when":"within 30 days of the change","record":"updated HUD-2880","cite":"24 CFR 4.11","receipt_step":false},{"n":3,"step":"Reconcile Part II against what the government publishes under your name.","who":"applicant","when":"at filing","record":"federal awards and subawards printed under the name and UEI at USAspending, dated","cite":"2 CFR 170; USAspending.gov as published","receipt_step":true}],"auditor_test":[{"test":"HUD program office review of the disclosure for completeness.","cite":"24 CFR 4.13"}],"forms":["hud-2880"]},"uflpa":{"title":"Forced-labor presumption and CBP requests for information (UFLPA)","steps":[{"n":1,"step":"Review each supplier's printed name against the UFLPA Entity List and the Consolidated Screening List before import.","who":"importer","when":"before entry; on list updates","record":"the dated CSL / Entity List read under the supplier's exact printed name","cite":"Pub. L. 117-78 §2(d)(2)(B); 19 U.S.C. 1307","receipt_step":true},{"n":2,"step":"Answer CBP Form 28 within 30 days with supply-chain documentation.","who":"importer","when":"within 30 days","record":"Form 28 response","cite":"19 CFR 151.11","receipt_step":false},{"n":3,"step":"CBP decides whether the presumption is rebutted.","who":"CBP","when":"after review","record":"CBP determination","cite":"Pub. L. 117-78 §3(b)","receipt_step":false}],"auditor_test":[{"test":"CBP detention, exclusion or seizure review under the UFLPA.","cite":"Pub. L. 117-78 §3; CBP UFLPA Operational Guidance for Importers"}],"forms":["cbp-form-28"]},"foci":{"title":"Foreign interests certificate for a facility clearance (SF-328; 32 CFR 117.11)","steps":[{"n":1,"step":"Complete the SF-328 at sponsorship for a facility clearance and whenever an answer changes.","who":"company (FSO / senior management official)","when":"at sponsorship; on change","record":"SF-328 in NISS","cite":"32 CFR 117.11(b)","receipt_step":false},{"n":2,"step":"Attach the registrant's own SAM hierarchy as filed and the exact-printed-name rows for each parent.","who":"company","when":"at filing","record":"SAM immediate and ultimate parent as registered; CSL, 1260H, UFLPA, FARA, OFAC, UN rows under each parent's printed name, dated","cite":"SAM.gov Entity Management as registered","receipt_step":true},{"n":3,"step":"DCSA determines whether foreign ownership, control or influence exists and what mitigation applies.","who":"DCSA","when":"after review","record":"DCSA determination","cite":"32 CFR 117.11(c)–(d)","receipt_step":false}],"auditor_test":[{"test":"DCSA FOCI review and periodic security review.","cite":"32 CFR 117.11; 32 CFR 117.7(b)"}],"forms":["sf-328"]},"osha_recordkeeping":{"title":"Injury and illness recordkeeping and electronic submission (29 CFR 1904)","steps":[{"n":1,"step":"Record each recordable work-related injury or illness on the OSHA 300 Log within seven calendar days.","who":"employer (establishment)","when":"within 7 days of learning of the case","record":"OSHA 300 Log and 301 Incident Report","cite":"29 CFR 1904.29(b)(3)","receipt_step":false},{"n":2,"step":"Complete, certify and post the 300A annual summary.","who":"employer; certified by a company executive","when":"post February 1 – April 30 for the prior year","record":"OSHA Form 300A","cite":"29 CFR 1904.32","receipt_step":false},{"n":3,"step":"Submit 300A data (and, for covered establishments, 300/301 data) electronically to the Injury Tracking Application; OSHA publishes establishment-level 300A data.","who":"establishments of 250+ employees, or 20–249 in designated industries","when":"by March 2","record":"ITA submission; OSHA's published ITA dataset by year","cite":"29 CFR 1904.41","receipt_step":true},{"n":4,"step":"OSHA inspects, cites and records the enforcement history of the establishment.","who":"OSHA","when":"on inspection","record":"OSHA inspection and citation record, dated","cite":"29 U.S.C. 657; 29 CFR 1903","receipt_step":true}],"auditor_test":[{"test":"Not a Single Audit requirement. Reviewed by OSHA on inspection (recordkeeping citations under 1904) and by contracting officers and owners through the public record; a Record History prints the figures by year as OSHA serves them.","cite":"29 CFR 1904.40; 29 CFR 1903"}],"forms":["osha-300a"]},"trafficking":{"title":"Combating trafficking in persons — clause, flow-down and notification (FAR 52.222-50; 2 CFR 175)","steps":[{"n":1,"step":"Include the clause in every solicitation and contract, and the award term in every federal award.","who":"contracting officer / awarding agency","when":"at award","record":"the clause or award term in the instrument","cite":"FAR 22.1705; 2 CFR 175.15","receipt_step":false},{"n":2,"step":"Flow the clause down to every subcontract and subaward at any tier.","who":"contractor / recipient","when":"at each lower-tier award","record":"the clause in the subcontract or subaward","cite":"FAR 52.222-50(i); 2 CFR 175.15(b)","receipt_step":false},{"n":3,"step":"Before and during the award, read the public record on the lower tier: SAM exclusions (cause and treatment codes as printed) and the Consolidated Screening List.","who":"contractor / recipient","when":"before award and periodically","record":"dated receipt per name","cite":"FAR 9.405; 2 CFR 180.300; FAR 52.222-50(e)","receipt_step":true},{"n":4,"step":"Notify the contracting officer or awarding official immediately of any credible information of a violation; the agency may terminate or refer for suspension or debarment.","who":"contractor / recipient; agency","when":"immediately on credible information","record":"notification; agency action in SAM","cite":"FAR 52.222-50(d), (e); 22 U.S.C. 7104(g)","receipt_step":false}],"auditor_test":[{"test":"Award-term inclusion and flow-down are tested under Special Tests and Provisions where the program includes them; exclusions under Procurement and Suspension and Debarment.","cite":"OMB Compliance Supplement, Part 3, Sections I and N"}],"forms":["far-52-222-50"]},"dbe":{"title":"Disadvantaged Business Enterprise certification, directory and participation (49 CFR Part 26)","steps":[{"n":1,"step":"The firm applies to the state Unified Certification Program on the Uniform Certification Application with supporting documents.","who":"firm","when":"once; annual no-change affidavit","record":"Uniform Certification Application (App. F); annual affidavit","cite":"49 CFR 26.83; 49 CFR 26, App. F","receipt_step":false},{"n":2,"step":"The UCP certifies or denies and lists each certified firm in the public unified directory.","who":"state UCP","when":"on determination; directory updated","record":"UCP directory row (name, NAICS, certifying agency)","cite":"49 CFR 26.81(g); 49 CFR 26.83","receipt_step":true},{"n":3,"step":"The recipient counts DBE participation only for certified DBEs performing a commercially useful function and monitors performance.","who":"state DOT / transit recipient / prime","when":"at commitment and during performance","record":"directory read dated at commitment; monitoring records","cite":"49 CFR 26.55; 49 CFR 26.37(a)","receipt_step":true}],"auditor_test":[{"test":"DBE program compliance is tested under Special Tests and Provisions for the Highway Planning and Construction cluster and FTA programs: participation counted only for certified DBEs; monitoring of commercially useful function.","cite":"OMB Compliance Supplement, Part 4, 20.205 and 20.5xx, Section N"}],"forms":["dot-dbe-ucp"]},"irs_teos":{"title":"Tax-exempt status and annual return (26 U.S.C. 6033, 6104)","steps":[{"n":1,"step":"File the annual return (990, 990-EZ, 990-N or 990-PF) by the 15th day of the fifth month after year end.","who":"exempt organization","when":"annually","record":"Form 990 as filed","cite":"26 U.S.C. 6033; 26 CFR 1.6033-2","receipt_step":false},{"n":2,"step":"The IRS publishes exempt status, ruling date, filings and auto-revocations; three consecutive missed filings revoke status automatically.","who":"IRS","when":"continuously; revocation list monthly","record":"Tax Exempt Organization Search entries by year","cite":"26 U.S.C. 6033(j); 26 U.S.C. 6104(b)","receipt_step":true},{"n":3,"step":"Funders and pass-through entities read the public status and return before award and in monitoring.","who":"awarding agency / pass-through entity","when":"before award; annually","record":"dated read of the TEOS entry and the filed return data","cite":"2 CFR 200.206; 2 CFR 200.332(b)","receipt_step":true}],"auditor_test":[{"test":"Not itself a Single Audit requirement; pre-award review and subrecipient risk assessment are tested under Subrecipient Monitoring.","cite":"OMB Compliance Supplement, Part 3, Section M; 2 CFR 200.206"}],"forms":["irs-990"]},"coop_purchasing":{"title":"Cooperative purchasing through a Commonwealth contract (62 Pa.C.S. § 1902; COSTARS)","steps":[{"n":1,"step":"The local public procurement unit registers as a COSTARS member.","who":"local public procurement unit","when":"once","record":"COSTARS membership","cite":"62 Pa.C.S. § 1901; DGS COSTARS member terms","receipt_step":false},{"n":2,"step":"The supplier holds a COSTARS contract awarded by DGS and appears in the public supplier/contract directory.","who":"supplier; DGS","when":"for the contract term","record":"COSTARS contract number; directory row (the public search refuses automated reads — robots.txt — so a receipt prints the official link as 'not read', not a row)","cite":"DGS COSTARS supplier terms","receipt_step":true},{"n":3,"step":"The member purchases under the contract without separate bidding and keeps the contract number and the dated directory read in the purchase file; the federal suspension-and-debarment read still applies where federal funds pay.","who":"member purchasing office","when":"at each purchase","record":"purchase order citing the COSTARS contract; dated directory receipt; 2 CFR 180.300 receipt where federal funds are used","cite":"62 Pa.C.S. § 1902(a); 2 CFR 180.300","receipt_step":true}],"auditor_test":[{"test":"Local auditors and the PA Auditor General test that non-bid purchases cite a cooperative contract in force; federal funds add the Procurement and Suspension and Debarment test.","cite":"62 Pa.C.S. § 1902; OMB Compliance Supplement, Part 3, Section I"}],"forms":["costars-contract"]}},"what_this_is_not":"Not legal advice, not a compliance determination, not a statement that any filer's certification is true or false. Form numbers and line numbers are as published on the date noted and may be renumbered by their agencies; the official page controls. Audit findings quoted are the auditor's words as filed at the Federal Audit Clearinghouse, cited by report id; they describe a documentation gap, not a conclusion about any party."}