ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? No Finding Number (if repeat) N/A
Finding 2023-004 – Material Weakness/Noncompliance – Allowable Costs/Cost Principals and Suspension and Debarment
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds:
• 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles;
• 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs;
• 2 CFR 200.318(c)(1) for employee conflicts of interest;
• 2 CFR 200.318(c)(2) for organizational conflicts of interest;
• 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals;
• 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals.
During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? No Finding Number (if repeat) N/A
Finding 2023-004 – Material Weakness/Noncompliance – Allowable Costs/Cost Principals and Suspension and Debarment
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds:
• 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles;
• 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs;
• 2 CFR 200.318(c)(1) for employee conflicts of interest;
• 2 CFR 200.318(c)(2) for organizational conflicts of interest;
• 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals;
• 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals.
During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? No Finding Number (if repeat) N/A
Finding 2023-004 – Material Weakness/Noncompliance – Allowable Costs/Cost Principals and Suspension and Debarment
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds:
• 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles;
• 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs;
• 2 CFR 200.318(c)(1) for employee conflicts of interest;
• 2 CFR 200.318(c)(2) for organizational conflicts of interest;
• 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals;
• 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals.
During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? No Finding Number (if repeat) N/A
Finding 2023-004 – Material Weakness/Noncompliance – Allowable Costs/Cost Principals and Suspension and Debarment
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds:
• 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles;
• 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs;
• 2 CFR 200.318(c)(1) for employee conflicts of interest;
• 2 CFR 200.318(c)(2) for organizational conflicts of interest;
• 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals;
• 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals.
During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? Yes Finding Number (if repeat) 2022-004
Finding 2023-003 – Material Weakness/Noncompliance – Suspension and Debarment
31 CFR 19 gives regulatory effect to the Department of Treasury for 2 CFR Section 180.305 which states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to 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 Section 180.135.
“Covered transactions” include nonprocurement 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 nonprocurement 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 § 180.220s. All nonprocurement transactions (i.e. subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR § 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, 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.gov),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300).
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. Due to the deficient internal control structure, the required verification was not completed for any of the vendors sampled with covered transactions in the Coronavirus State and Local Fiscal Recovery Funds during Fiscal Year 2023. Those transactions had a payment to a vendor of equal or greater than $25,000 and there was no evidence the County 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 internal controls in place may result in suspended or debarred vendors receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the County should 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.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? Yes Finding Number (if repeat) 2022-004
Finding 2023-003 – Material Weakness/Noncompliance – Suspension and Debarment
31 CFR 19 gives regulatory effect to the Department of Treasury for 2 CFR Section 180.305 which states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to 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 Section 180.135.
“Covered transactions” include nonprocurement 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 nonprocurement 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 § 180.220s. All nonprocurement transactions (i.e. subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR § 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, 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.gov),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300).
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. Due to the deficient internal control structure, the required verification was not completed for any of the vendors sampled with covered transactions in the Coronavirus State and Local Fiscal Recovery Funds during Fiscal Year 2023. Those transactions had a payment to a vendor of equal or greater than $25,000 and there was no evidence the County 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 internal controls in place may result in suspended or debarred vendors receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the County should 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.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? Yes Finding Number (if repeat) 2022-004
Finding 2023-003 – Material Weakness/Noncompliance – Suspension and Debarment
31 CFR 19 gives regulatory effect to the Department of Treasury for 2 CFR Section 180.305 which states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to 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 Section 180.135.
“Covered transactions” include nonprocurement 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 nonprocurement 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 § 180.220s. All nonprocurement transactions (i.e. subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR § 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, 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.gov),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300).
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. Due to the deficient internal control structure, the required verification was not completed for any of the vendors sampled with covered transactions in the Coronavirus State and Local Fiscal Recovery Funds during Fiscal Year 2023. Those transactions had a payment to a vendor of equal or greater than $25,000 and there was no evidence the County 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 internal controls in place may result in suspended or debarred vendors receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the County should 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.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? Yes Finding Number (if repeat) 2022-004
Finding 2023-003 – Material Weakness/Noncompliance – Suspension and Debarment
31 CFR 19 gives regulatory effect to the Department of Treasury for 2 CFR Section 180.305 which states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to 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 Section 180.135.
“Covered transactions” include nonprocurement 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 nonprocurement 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 § 180.220s. All nonprocurement transactions (i.e. subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR § 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, 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.gov),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300).
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. Due to the deficient internal control structure, the required verification was not completed for any of the vendors sampled with covered transactions in the Coronavirus State and Local Fiscal Recovery Funds during Fiscal Year 2023. Those transactions had a payment to a vendor of equal or greater than $25,000 and there was no evidence the County 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 internal controls in place may result in suspended or debarred vendors receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the County should 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.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? No Finding Number (if repeat) N/A
Finding 2023-004 – Material Weakness/Noncompliance – Allowable Costs/Cost Principals and Suspension and Debarment
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds:
• 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles;
• 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs;
• 2 CFR 200.318(c)(1) for employee conflicts of interest;
• 2 CFR 200.318(c)(2) for organizational conflicts of interest;
• 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals;
• 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals.
During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? No Finding Number (if repeat) N/A
Finding 2023-004 – Material Weakness/Noncompliance – Allowable Costs/Cost Principals and Suspension and Debarment
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds:
• 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles;
• 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs;
• 2 CFR 200.318(c)(1) for employee conflicts of interest;
• 2 CFR 200.318(c)(2) for organizational conflicts of interest;
• 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals;
• 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals.
During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? No Finding Number (if repeat) N/A
Finding 2023-004 – Material Weakness/Noncompliance – Allowable Costs/Cost Principals and Suspension and Debarment
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds:
• 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles;
• 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs;
• 2 CFR 200.318(c)(1) for employee conflicts of interest;
• 2 CFR 200.318(c)(2) for organizational conflicts of interest;
• 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals;
• 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals.
During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? No Finding Number (if repeat) N/A
Finding 2023-004 – Material Weakness/Noncompliance – Allowable Costs/Cost Principals and Suspension and Debarment
2 CFR 200 outlines the following policies required for a County spending Coronavirus State and Local Fiscal Recovery Funds:
• 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles;
• 2 CFR 200.430 for allowability of compensation costs; 2 CFR 200.464(a)(2) for reimbursement of relocation costs;
• 2 CFR 200.318(c)(1) for employee conflicts of interest;
• 2 CFR 200.318(c)(2) for organizational conflicts of interest;
• 2 CFR 200.320(b)(2) for selection and awarding of contracts for competitive proposals;
• 2 CFR 200.319(d) for minimum evaluation criteria for bids and proposals.
During testing we noted that the County did not have sufficient written policies addressing the above requirements. Failure to adopt and implement policies could lead to noncompliance with federal requirements. We recommend the County approve and implement the above policies to ensure compliance with federal requirements.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? Yes Finding Number (if repeat) 2022-004
Finding 2023-003 – Material Weakness/Noncompliance – Suspension and Debarment
31 CFR 19 gives regulatory effect to the Department of Treasury for 2 CFR Section 180.305 which states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to 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 Section 180.135.
“Covered transactions” include nonprocurement 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 nonprocurement 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 § 180.220s. All nonprocurement transactions (i.e. subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR § 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, 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.gov),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300).
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. Due to the deficient internal control structure, the required verification was not completed for any of the vendors sampled with covered transactions in the Coronavirus State and Local Fiscal Recovery Funds during Fiscal Year 2023. Those transactions had a payment to a vendor of equal or greater than $25,000 and there was no evidence the County 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 internal controls in place may result in suspended or debarred vendors receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the County should 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.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? Yes Finding Number (if repeat) 2022-004
Finding 2023-003 – Material Weakness/Noncompliance – Suspension and Debarment
31 CFR 19 gives regulatory effect to the Department of Treasury for 2 CFR Section 180.305 which states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to 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 Section 180.135.
“Covered transactions” include nonprocurement 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 nonprocurement 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 § 180.220s. All nonprocurement transactions (i.e. subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR § 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, 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.gov),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300).
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. Due to the deficient internal control structure, the required verification was not completed for any of the vendors sampled with covered transactions in the Coronavirus State and Local Fiscal Recovery Funds during Fiscal Year 2023. Those transactions had a payment to a vendor of equal or greater than $25,000 and there was no evidence the County 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 internal controls in place may result in suspended or debarred vendors receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the County should 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.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? Yes Finding Number (if repeat) 2022-004
Finding 2023-003 – Material Weakness/Noncompliance – Suspension and Debarment
31 CFR 19 gives regulatory effect to the Department of Treasury for 2 CFR Section 180.305 which states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to 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 Section 180.135.
“Covered transactions” include nonprocurement 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 nonprocurement 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 § 180.220s. All nonprocurement transactions (i.e. subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR § 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, 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.gov),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300).
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. Due to the deficient internal control structure, the required verification was not completed for any of the vendors sampled with covered transactions in the Coronavirus State and Local Fiscal Recovery Funds during Fiscal Year 2023. Those transactions had a payment to a vendor of equal or greater than $25,000 and there was no evidence the County 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 internal controls in place may result in suspended or debarred vendors receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the County should 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.
ALN Title and Number COVID-19 Coronavirus State and Local Fiscal Recovery Funds, AL #21.027
Federal Award Number and Year 2023
Federal Agency United States Department of the Treasury
Pass-Through Entity Ohio Department of Public Safety
Repeat Finding from Prior Audit? Yes Finding Number (if repeat) 2022-004
Finding 2023-003 – Material Weakness/Noncompliance – Suspension and Debarment
31 CFR 19 gives regulatory effect to the Department of Treasury for 2 CFR Section 180.305 which states that Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to 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 Section 180.135.
“Covered transactions” include nonprocurement 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 nonprocurement 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 § 180.220s. All nonprocurement transactions (i.e. subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR § 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, 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.gov),
(2) collecting a certification from the entity, or
(3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300).
The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. Due to the deficient internal control structure, the required verification was not completed for any of the vendors sampled with covered transactions in the Coronavirus State and Local Fiscal Recovery Funds during Fiscal Year 2023. Those transactions had a payment to a vendor of equal or greater than $25,000 and there was no evidence the County 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 internal controls in place may result in suspended or debarred vendors receiving federal funds.
Prior to contracting with vendors that will be paid with federal funds, the County should 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.