Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department of the Treasury, Coronavirus State and Local Fiscal Recovery Fund
Federal Award Identification Number and Year - SLFRP2024-2001
Pass-through Entity - Not applicable
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes 2022-002
Criteria - The City should ensure there is a process in place, prior to entering
contracts with subrecipients, to verify that such subrecipients are not
suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition - We noted during testing that the City had unintentionally omitted
a subrecipient from its search to ensure that the subrecipient was not
suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Not applicable
Context - From July 1, 2022 through June 30, 2023, any subrecipient with which the City entered into a contract using federal award funds should have been verified as not being suspended, debarred, or otherwise excluded pursuant to 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. We selected three subrecipients for testing, and one lacked any verification. However, based on our testing, we noted that the one subrecipient was not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, thereby creating no questioned costs.
Cause and Effect - The City is required to verify that any subrecipient with which it plans to enter into a contract using federal award funds is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The City did not complete this requirement due to timing of final approval of the subrecipient pass-through funds.
Recommendation - We recommend that an additional internal control be put in place to ensure the dual verification of subrecipients occurs.
Views of Responsible Officials and Corrective Action Plan - Procedures have already been put into place to ensure that each new contractor is not on the federal list of suspended and/or debarred contractors. Furthermore, all vendors previously paid have been searched for in the federal list, and none were suspended and/or debarred.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department of the Treasury, Coronavirus State and Local Fiscal Recovery Fund
Federal Award Identification Number and Year - SLFRP2024-2001
Pass-through Entity - Not applicable
Finding Type - Material weakness and material noncompliance with laws
and regulations
Repeat Finding - No
Criteria - The City should ensure there is a process in place, prior to theprocurement of goods and services, to verify that the City has followed its
internal procurement policy pursuant to 2 CFR 200.319 and 200.320.
Condition - We identified 4 expenditures, during testing, that the City did not verify were in accordance with its internal procurement policy, pursuant to 2
CFR 200.319 and 200.320 prior to entering into contracts with award funds.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Not applicable
Context - From July 1, 2022 through June 30, 2023, any good or service purchased by the City is subject to the City's internal procurement policy,
pursuant to 2 CFR 200.319 and 200.320. We selected 22 expenditures for testing, and 4 lacked evidence of the City following its internal procurement
policy. However, based on our testing, we noted that all 4 expenditures were allowable under the terms of the grant, thereby creating no questioned costs.
Cause and Effect - The City is required to verify that there is a process in place to ensure all eligible expenditures adhere to its internal procurement
policy, pursuant to 2 CFR 200.319 and 200.320. The City did not complete this requirement due to override of preexisting controls implemented by the City.
Recommendation - We recommend that an additional internal control be put in place to ensure that all eligible expenditures adhere to the City's internal
procurement policy.
Views of Responsible Officials and Planned Corrective Actions - Procedures have already been put into place to ensure that each purchase adheres to the internal purchasing policies. City management and staff will continue to improve communication with and between departments to ensure all staff understand the purchasing policy.
Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department of the Treasury, Coronavirus State and Local Fiscal Recovery Fund
Federal Award Identification Number and Year - SLFRP2024-2001
Pass-through Entity - Not applicable
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes 2022-002
Criteria - The City should ensure there is a process in place, prior to entering
contracts with subrecipients, to verify that such subrecipients are not
suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition - We noted during testing that the City had unintentionally omitted
a subrecipient from its search to ensure that the subrecipient was not
suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Not applicable
Context - From July 1, 2022 through June 30, 2023, any subrecipient with which the City entered into a contract using federal award funds should have been verified as not being suspended, debarred, or otherwise excluded pursuant to 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. We selected three subrecipients for testing, and one lacked any verification. However, based on our testing, we noted that the one subrecipient was not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, thereby creating no questioned costs.
Cause and Effect - The City is required to verify that any subrecipient with which it plans to enter into a contract using federal award funds is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The City did not complete this requirement due to timing of final approval of the subrecipient pass-through funds.
Recommendation - We recommend that an additional internal control be put in place to ensure the dual verification of subrecipients occurs.
Views of Responsible Officials and Corrective Action Plan - Procedures have already been put into place to ensure that each new contractor is not on the federal list of suspended and/or debarred contractors. Furthermore, all vendors previously paid have been searched for in the federal list, and none were suspended and/or debarred.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department of the Treasury, Coronavirus State and Local Fiscal Recovery Fund
Federal Award Identification Number and Year - SLFRP2024-2001
Pass-through Entity - Not applicable
Finding Type - Material weakness and material noncompliance with laws
and regulations
Repeat Finding - No
Criteria - The City should ensure there is a process in place, prior to theprocurement of goods and services, to verify that the City has followed its
internal procurement policy pursuant to 2 CFR 200.319 and 200.320.
Condition - We identified 4 expenditures, during testing, that the City did not verify were in accordance with its internal procurement policy, pursuant to 2
CFR 200.319 and 200.320 prior to entering into contracts with award funds.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Not applicable
Context - From July 1, 2022 through June 30, 2023, any good or service purchased by the City is subject to the City's internal procurement policy,
pursuant to 2 CFR 200.319 and 200.320. We selected 22 expenditures for testing, and 4 lacked evidence of the City following its internal procurement
policy. However, based on our testing, we noted that all 4 expenditures were allowable under the terms of the grant, thereby creating no questioned costs.
Cause and Effect - The City is required to verify that there is a process in place to ensure all eligible expenditures adhere to its internal procurement
policy, pursuant to 2 CFR 200.319 and 200.320. The City did not complete this requirement due to override of preexisting controls implemented by the City.
Recommendation - We recommend that an additional internal control be put in place to ensure that all eligible expenditures adhere to the City's internal
procurement policy.
Views of Responsible Officials and Planned Corrective Actions - Procedures have already been put into place to ensure that each purchase adheres to the internal purchasing policies. City management and staff will continue to improve communication with and between departments to ensure all staff understand the purchasing policy.