Audit 291144

Suspension and Debarment (Material Weakness) Federal Agency: U.S. Treasury Pass-through Agency: N/A Cluster/Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Passed-through Identification: N/A Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the federal ward that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, under 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The Town did not properly verify and document federal suspension and debarment status for one vendor prior to entering into a transaction with the vendor. Cause: The Town does not have formal policies and procedures in place to ensure vendors are not suspended or debarred. Effect: The Town’s system of internal controls was not designed effectively to prevent instances of noncompliance. However, it was determined that no vendor utilized was suspended or debarred. Questioned Costs: None Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Town implement policies and procedures to formally verify and document the suspension and debarment process for all entities that it enters into transactions with using federal funds. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.

Suspension and Debarment (Material Weakness) Federal Agency: U.S. Treasury Pass-through Agency: N/A Cluster/Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Passed-through Identification: N/A Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the federal ward that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, under 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. When a non-Federal entity enters into a covered transaction with an entity, the non-Federal entity must verify that the entity, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: The Town did not properly verify and document federal suspension and debarment status for one vendor prior to entering into a transaction with the vendor. Cause: The Town does not have formal policies and procedures in place to ensure vendors are not suspended or debarred. Effect: The Town’s system of internal controls was not designed effectively to prevent instances of noncompliance. However, it was determined that no vendor utilized was suspended or debarred. Questioned Costs: None Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Town implement policies and procedures to formally verify and document the suspension and debarment process for all entities that it enters into transactions with using federal funds. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.