2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.
While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. Payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 13 out of the 19 selected worklogs (68%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 7 and 102 working days (not including weekends) following the end of the pay period.
Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost.
The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR § 2867.10 gives regulatory effect for the Department of Justice and 2 CFR § 1500.13(c)(5) gives regulatory effect for the Environmental Protection Agency for 2 CFR 180.305 which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135.
2 CFR § 180.200 identified “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR § 180.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 CFR § 180.215.
Concerning the Department of Treasury, 31 CFR 19.305(a) which states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 31 CFR § 19.120.31 CFR § 19.200 identifies “covered transactions” as non-procurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 31 CFR § 19.220. All non-procurement transactions (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR § 19.215.
When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov ); collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity.
Furthermore, the City of Columbus Purchasing Policy Manual - Bid and Proposal Evaluations - Federal Grants - Special Instructions provides "each department will review its Federal grants program policies and procedures for contract routing and update them immediately to include the following: A SAM.gov website review shall be included as the first page with each original contract scanned into Dynamics 365."
While the City does have an internal control policy in place regarding the SAM exclusion verifications of suspended or debarred entities, the City did not always adhere to the policy when entering into covered transactions. During testing of the AL #16.922 Equitable Sharing Program, AL #21.027 Coronavirus State and Local Fiscal Recovery Funds, and AL #66.468 Capitalization Grants for Drinking Water State Revolving Fund grant programs, we noted one out of five instances (20%), one out of twelve instances (8%), and one out of one instance (100%), respectively, in which the programs had a payment to a vendor of more than $25,000 and no evidence the City checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor.
Failing to have the appropriate controls in place may result in vendors who are suspended or debarred receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the City should follow its established policy and must verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Evidence of actions taken to ensure proper suspension and debarment requirements must be maintained by all department of the City.
2 CFR §2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR §200.303(a) which states that the non-Federal entity must establish and maintain effective internal control over the Federal award 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Furthermore, 2 CFR §200.430(i)(1)(i) states "charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
The “City of Columbus Fiscal Policies and Procedures for the Administration of HUD Grants Manual” Part II Section C – Standards for Documentation of Personal Services provides the following: All grant funded staff (both city staff and subrecipient staff) will utilize personal activity reports (timesheets). All timesheets will reflect total hours worked, identify the federal grant hours worked, and be signed by either the employee or the supervisor. Furthermore, the City of Columbus Department of Development has established a procedure of timesheet review which requires supervisors review employee timesheets within one week of the pay period end date. This review is evidenced by an electronic signature on the employee-completed timesheet.
While the City does have an internal control policy in place in accordance with 2 CFR 430(i)(1)(i), supervisors were not always adhering to the policy which resulted in a deficiency in the application of the control process. Payroll control testing over AL #14.239 Home Investment Partnership Program, it was noted 13 out of the 19 selected worklogs (68%) were not signed by the supervisor within the one-week requirement as required by City policy. Supervisory sign offs occurred between 7 and 102 working days (not including weekends) following the end of the pay period.
Failure to follow the established internal control policy and ensuring all time sheets are appropriately approved by a knowledgeable supervisor, within one week of the pay period end date, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost.
The City should review established policies and procedures with supervisory personnel and evaluate if additional control procedures should be in place to ensure all timesheets are appropriately reviewed timely prior to allocation to a federal program.