Procurement, Suspension, and Debarment
Finding Type:
Material Weakness in Internal Control over Compliance.
Programs:
United States Environmental Protection Agency
Capitalization Grants for Clean Water State Revolving Funds (ALN
#66.458) and Capitalization Grants for Drinking Water State Revolving
Funds (ALN #66.468)
Criteria:
The Uniform Guidance, §200.214, requires that a recipient of federal
awards 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.
Condition/Finding:
During our audit procedures over the City’s debarment and suspension
procedures, we noted that the City relies on their engineers to make sure
contractors are not debarred, suspended, or otherwise excluded from
Federal assistance programs or activities. The City does not have a process
in place to verify the engineers are in fact monitoring the contractors on the
project.
Cause:
The City does not have the proper internal controls in place to ensure that
all contractors are not debarred, suspended, or otherwise excluded from
Federal assistance programs or activities.
Effect:
The City did not follow requirements to check whether a vendor is
suspended or debarred.
Questioned Costs:
No costs have been questioned as a result of this finding.
Recommendation:
We recommend that the City verify that any vendors or contractors selected
are verified as neither suspended or debarred per the SAM.gov website prior
to awarding the bid, and, that the City retain documentation of their
verification in the bid file.
Cash Management
Finding Type:
Noncompliance and Material Weakness in Internal Control over
Compliance.
Programs:
United States Environmental Protection Agency
Capitalization Grants for Clean Water State Revolving Funds (ALN
#66.458) and Capitalization Grants for Drinking Water State Revolving
Funds (ALN #66.468)
Criteria:
For cost-reimbursement contracts under the Federal Acquisition Regulation
(“FAR”), reimbursement payment is the predominant method of funding.
Advance payments under FAR based contracts are rare. The FAR clause at
48 CFR section 52.216-7 applies to reimbursement payment. Paragraph
(b)(1) of that clause requires that the non-Federal entity request
reimbursement for (a) only allocable, allowable, and reasonable contract
costs that have already been paid, or (b) if the non-Federal entity is not
delinquent in paying costs of contract performance in the ordinary course
of business, costs incurred, but not necessarily paid. As defined in 48 CFR
section 52.216-7(b)(1), with relation to supplies and services purchased for
use on the contract, “ordinary course of business” would be in accordance
with the terms and conditions of a subcontract or invoice, and ordinarily
within 30 days of the request to the Federal Government for reimbursement.
Condition/Finding: During our audit procedures over the City’s cash management procedures,
we noted that the City paid contractors and vendors 30 days after receiving
the Federal reimbursement on two of the five federal reimbursements, with
vouchers totaling $212,541. The City does not have a process in place to
ensure contractors and vendors are paid in a timely manner.
Cause:
The City does not have a cash management policy which led to them
receiving and disbursing funds not in compliance with the Uniform
Guidance.
Effect:
Contractors and vendors were not paid timely and federal funds were held
for over thirty days prior to the disbursement of funds.
Questioned Costs:
No costs have been questioned as a result of this finding.
Recommendation:
The City should develop and implement a cash management policy and
procedures and if reimbursements are requested prior to paying the
contractors and vendors the contractors and vendors are paid within 30 days
of the request.
Procurement, Suspension, and Debarment
Finding Type:
Material Weakness in Internal Control over Compliance.
Programs:
United States Environmental Protection Agency
Capitalization Grants for Clean Water State Revolving Funds (ALN
#66.458) and Capitalization Grants for Drinking Water State Revolving
Funds (ALN #66.468)
Criteria:
The Uniform Guidance, §200.214, requires that a recipient of federal
awards 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.
Condition/Finding:
During our audit procedures over the City’s debarment and suspension
procedures, we noted that the City relies on their engineers to make sure
contractors are not debarred, suspended, or otherwise excluded from
Federal assistance programs or activities. The City does not have a process
in place to verify the engineers are in fact monitoring the contractors on the
project.
Cause:
The City does not have the proper internal controls in place to ensure that
all contractors are not debarred, suspended, or otherwise excluded from
Federal assistance programs or activities.
Effect:
The City did not follow requirements to check whether a vendor is
suspended or debarred.
Questioned Costs:
No costs have been questioned as a result of this finding.
Recommendation:
We recommend that the City verify that any vendors or contractors selected
are verified as neither suspended or debarred per the SAM.gov website prior
to awarding the bid, and, that the City retain documentation of their
verification in the bid file.
Cash Management
Finding Type:
Noncompliance and Material Weakness in Internal Control over
Compliance.
Programs:
United States Environmental Protection Agency
Capitalization Grants for Clean Water State Revolving Funds (ALN
#66.458) and Capitalization Grants for Drinking Water State Revolving
Funds (ALN #66.468)
Criteria:
For cost-reimbursement contracts under the Federal Acquisition Regulation
(“FAR”), reimbursement payment is the predominant method of funding.
Advance payments under FAR based contracts are rare. The FAR clause at
48 CFR section 52.216-7 applies to reimbursement payment. Paragraph
(b)(1) of that clause requires that the non-Federal entity request
reimbursement for (a) only allocable, allowable, and reasonable contract
costs that have already been paid, or (b) if the non-Federal entity is not
delinquent in paying costs of contract performance in the ordinary course
of business, costs incurred, but not necessarily paid. As defined in 48 CFR
section 52.216-7(b)(1), with relation to supplies and services purchased for
use on the contract, “ordinary course of business” would be in accordance
with the terms and conditions of a subcontract or invoice, and ordinarily
within 30 days of the request to the Federal Government for reimbursement.
Condition/Finding: During our audit procedures over the City’s cash management procedures,
we noted that the City paid contractors and vendors 30 days after receiving
the Federal reimbursement on two of the five federal reimbursements, with
vouchers totaling $212,541. The City does not have a process in place to
ensure contractors and vendors are paid in a timely manner.
Cause:
The City does not have a cash management policy which led to them
receiving and disbursing funds not in compliance with the Uniform
Guidance.
Effect:
Contractors and vendors were not paid timely and federal funds were held
for over thirty days prior to the disbursement of funds.
Questioned Costs:
No costs have been questioned as a result of this finding.
Recommendation:
The City should develop and implement a cash management policy and
procedures and if reimbursements are requested prior to paying the
contractors and vendors the contractors and vendors are paid within 30 days
of the request.
Procurement, Suspension, and Debarment
Finding Type:
Material Weakness in Internal Control over Compliance.
Programs:
United States Environmental Protection Agency
Capitalization Grants for Clean Water State Revolving Funds (ALN
#66.458) and Capitalization Grants for Drinking Water State Revolving
Funds (ALN #66.468)
Criteria:
The Uniform Guidance, §200.214, requires that a recipient of federal
awards 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.
Condition/Finding:
During our audit procedures over the City’s debarment and suspension
procedures, we noted that the City relies on their engineers to make sure
contractors are not debarred, suspended, or otherwise excluded from
Federal assistance programs or activities. The City does not have a process
in place to verify the engineers are in fact monitoring the contractors on the
project.
Cause:
The City does not have the proper internal controls in place to ensure that
all contractors are not debarred, suspended, or otherwise excluded from
Federal assistance programs or activities.
Effect:
The City did not follow requirements to check whether a vendor is
suspended or debarred.
Questioned Costs:
No costs have been questioned as a result of this finding.
Recommendation:
We recommend that the City verify that any vendors or contractors selected
are verified as neither suspended or debarred per the SAM.gov website prior
to awarding the bid, and, that the City retain documentation of their
verification in the bid file.
Cash Management
Finding Type:
Noncompliance and Material Weakness in Internal Control over
Compliance.
Programs:
United States Environmental Protection Agency
Capitalization Grants for Clean Water State Revolving Funds (ALN
#66.458) and Capitalization Grants for Drinking Water State Revolving
Funds (ALN #66.468)
Criteria:
For cost-reimbursement contracts under the Federal Acquisition Regulation
(“FAR”), reimbursement payment is the predominant method of funding.
Advance payments under FAR based contracts are rare. The FAR clause at
48 CFR section 52.216-7 applies to reimbursement payment. Paragraph
(b)(1) of that clause requires that the non-Federal entity request
reimbursement for (a) only allocable, allowable, and reasonable contract
costs that have already been paid, or (b) if the non-Federal entity is not
delinquent in paying costs of contract performance in the ordinary course
of business, costs incurred, but not necessarily paid. As defined in 48 CFR
section 52.216-7(b)(1), with relation to supplies and services purchased for
use on the contract, “ordinary course of business” would be in accordance
with the terms and conditions of a subcontract or invoice, and ordinarily
within 30 days of the request to the Federal Government for reimbursement.
Condition/Finding: During our audit procedures over the City’s cash management procedures,
we noted that the City paid contractors and vendors 30 days after receiving
the Federal reimbursement on two of the five federal reimbursements, with
vouchers totaling $212,541. The City does not have a process in place to
ensure contractors and vendors are paid in a timely manner.
Cause:
The City does not have a cash management policy which led to them
receiving and disbursing funds not in compliance with the Uniform
Guidance.
Effect:
Contractors and vendors were not paid timely and federal funds were held
for over thirty days prior to the disbursement of funds.
Questioned Costs:
No costs have been questioned as a result of this finding.
Recommendation:
The City should develop and implement a cash management policy and
procedures and if reimbursements are requested prior to paying the
contractors and vendors the contractors and vendors are paid within 30 days
of the request.
Procurement, Suspension, and Debarment
Finding Type:
Material Weakness in Internal Control over Compliance.
Programs:
United States Environmental Protection Agency
Capitalization Grants for Clean Water State Revolving Funds (ALN
#66.458) and Capitalization Grants for Drinking Water State Revolving
Funds (ALN #66.468)
Criteria:
The Uniform Guidance, §200.214, requires that a recipient of federal
awards 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.
Condition/Finding:
During our audit procedures over the City’s debarment and suspension
procedures, we noted that the City relies on their engineers to make sure
contractors are not debarred, suspended, or otherwise excluded from
Federal assistance programs or activities. The City does not have a process
in place to verify the engineers are in fact monitoring the contractors on the
project.
Cause:
The City does not have the proper internal controls in place to ensure that
all contractors are not debarred, suspended, or otherwise excluded from
Federal assistance programs or activities.
Effect:
The City did not follow requirements to check whether a vendor is
suspended or debarred.
Questioned Costs:
No costs have been questioned as a result of this finding.
Recommendation:
We recommend that the City verify that any vendors or contractors selected
are verified as neither suspended or debarred per the SAM.gov website prior
to awarding the bid, and, that the City retain documentation of their
verification in the bid file.
Cash Management
Finding Type:
Noncompliance and Material Weakness in Internal Control over
Compliance.
Programs:
United States Environmental Protection Agency
Capitalization Grants for Clean Water State Revolving Funds (ALN
#66.458) and Capitalization Grants for Drinking Water State Revolving
Funds (ALN #66.468)
Criteria:
For cost-reimbursement contracts under the Federal Acquisition Regulation
(“FAR”), reimbursement payment is the predominant method of funding.
Advance payments under FAR based contracts are rare. The FAR clause at
48 CFR section 52.216-7 applies to reimbursement payment. Paragraph
(b)(1) of that clause requires that the non-Federal entity request
reimbursement for (a) only allocable, allowable, and reasonable contract
costs that have already been paid, or (b) if the non-Federal entity is not
delinquent in paying costs of contract performance in the ordinary course
of business, costs incurred, but not necessarily paid. As defined in 48 CFR
section 52.216-7(b)(1), with relation to supplies and services purchased for
use on the contract, “ordinary course of business” would be in accordance
with the terms and conditions of a subcontract or invoice, and ordinarily
within 30 days of the request to the Federal Government for reimbursement.
Condition/Finding: During our audit procedures over the City’s cash management procedures,
we noted that the City paid contractors and vendors 30 days after receiving
the Federal reimbursement on two of the five federal reimbursements, with
vouchers totaling $212,541. The City does not have a process in place to
ensure contractors and vendors are paid in a timely manner.
Cause:
The City does not have a cash management policy which led to them
receiving and disbursing funds not in compliance with the Uniform
Guidance.
Effect:
Contractors and vendors were not paid timely and federal funds were held
for over thirty days prior to the disbursement of funds.
Questioned Costs:
No costs have been questioned as a result of this finding.
Recommendation:
The City should develop and implement a cash management policy and
procedures and if reimbursements are requested prior to paying the
contractors and vendors the contractors and vendors are paid within 30 days
of the request.