Audit 360037

2024-002 Suspension and Debarment Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLFRP3546; 2021 Pass-Through Agency: N/A - Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The County’s written procurement policy, however, requires both checking SAM.gov exclusions and obtaining a certification from the contractor prior to entering into a covered transaction. Condition: For three covered transactions tested, the County did not follow its written procurement policy to perform verification for suspended or debarred vendors by checking SAM.gov prior to entering into the covered transactions. Also, certifications were not obtained from contractors for two of the three covered transactions tested. Questioned Costs: None. Context: The County entered into a total of 11 covered transactions for the Coronavirus State and Local Fiscal Recovery Funds program during 2024. At the time of the audit, the County provided a signed certification for one of the three transactions tested and provided support that the vendors tested were not recently listed as suspended or debarred on SAM.gov. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant. Cause: At the time of entering into the covered transactions, the County was not aware which transactions would be used as grant expenditures, and the County did not perform a SAM.gov search. Additionally, the County indicated two of the transactions tested were professional service agreements, and the County was not required to follow a formal bidding process; therefore, certifications were not obtained. Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended, or otherwise excluded from conducting business with the County; the County should complete this documentation prior to entering into a covered transaction. View of Responsible Official: Acknowledge

2024-002 Suspension and Debarment Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLFRP3546; 2021 Pass-Through Agency: N/A - Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction. The County’s written procurement policy, however, requires both checking SAM.gov exclusions and obtaining a certification from the contractor prior to entering into a covered transaction. Condition: For three covered transactions tested, the County did not follow its written procurement policy to perform verification for suspended or debarred vendors by checking SAM.gov prior to entering into the covered transactions. Also, certifications were not obtained from contractors for two of the three covered transactions tested. Questioned Costs: None. Context: The County entered into a total of 11 covered transactions for the Coronavirus State and Local Fiscal Recovery Funds program during 2024. At the time of the audit, the County provided a signed certification for one of the three transactions tested and provided support that the vendors tested were not recently listed as suspended or debarred on SAM.gov. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant. Cause: At the time of entering into the covered transactions, the County was not aware which transactions would be used as grant expenditures, and the County did not perform a SAM.gov search. Additionally, the County indicated two of the transactions tested were professional service agreements, and the County was not required to follow a formal bidding process; therefore, certifications were not obtained. Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended, or otherwise excluded from conducting business with the County; the County should complete this documentation prior to entering into a covered transaction. View of Responsible Official: Acknowledge