Finding 2024-004 Reporting – Internal Control and Compliance Over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-23-MC-06-0555; B-22-MC-06-0555; B-20-MW-06-0555; B-19-MC-06-0555; B-18-MC-06-0555; B-17-MC-06-0555; B-16-MC-06-0555 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): PR29, CDBG and CDBG-CV Cash on Hand Quarterly Reports – PR29 in the Integrated Disbursement and Information System (IDIS) reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to the Department of Housing and Urban Development (“HUD”) on a quarterly basis, 30 days after the reporting period end date. The due date of each quarterly report is noted below: Reporting Period (End Date) Due Date of Reports September 30, 2023 October 30, 2023 December 31, 2023 January 30, 2024 March 31, 2024 April 30, 2024 June 30, 2024 July 30, 2024 Condition: During the audit, we noticed that three out of four quarters of PR29 for CDBG and CDBG-CV were not filed within the deadline, as shown below: Reporting Period Submission PR29 Report (End Date) Due Date of Reports Date CDBG September 30, 2023 October 30, 2023 November 6, 2023 CDBG March 31, 2024 April 30, 2024 May 1, 2024 CDBG June 30, 2024 July 30, 2024 September 18, 2024 CDBG-CV September 30, 2023 October 30, 2023 November 6, 2023 CDBG-CV March 31, 2024 April 30, 2024 May 1, 2024 CDBG-CV June 30, 2024 July 30, 2024 September 18, 2024 Cause: The City’s monitoring controls were inadequate to ensure the timely submission of the required reports. Effect or Potential Effect: The City was not in compliance with the programs’ reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-006. Recommendation: We recommend the City strengthen its internal controls over grant reporting by implementing a formal tracking system and assigning clear responsibility for the preparation and timely submission of the required reports. Regular review of reporting deadlines should be incorporated to ensure ongoing compliance with program requirements. Views of Responsible Officials: Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe
Finding 2024-004 Reporting – Internal Control and Compliance Over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-23-MC-06-0555; B-22-MC-06-0555; B-20-MW-06-0555; B-19-MC-06-0555; B-18-MC-06-0555; B-17-MC-06-0555; B-16-MC-06-0555 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): PR29, CDBG and CDBG-CV Cash on Hand Quarterly Reports – PR29 in the Integrated Disbursement and Information System (IDIS) reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to the Department of Housing and Urban Development (“HUD”) on a quarterly basis, 30 days after the reporting period end date. The due date of each quarterly report is noted below: Reporting Period (End Date) Due Date of Reports September 30, 2023 October 30, 2023 December 31, 2023 January 30, 2024 March 31, 2024 April 30, 2024 June 30, 2024 July 30, 2024 Condition: During the audit, we noticed that three out of four quarters of PR29 for CDBG and CDBG-CV were not filed within the deadline, as shown below: Reporting Period Submission PR29 Report (End Date) Due Date of Reports Date CDBG September 30, 2023 October 30, 2023 November 6, 2023 CDBG March 31, 2024 April 30, 2024 May 1, 2024 CDBG June 30, 2024 July 30, 2024 September 18, 2024 CDBG-CV September 30, 2023 October 30, 2023 November 6, 2023 CDBG-CV March 31, 2024 April 30, 2024 May 1, 2024 CDBG-CV June 30, 2024 July 30, 2024 September 18, 2024 Cause: The City’s monitoring controls were inadequate to ensure the timely submission of the required reports. Effect or Potential Effect: The City was not in compliance with the programs’ reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-006. Recommendation: We recommend the City strengthen its internal controls over grant reporting by implementing a formal tracking system and assigning clear responsibility for the preparation and timely submission of the required reports. Regular review of reporting deadlines should be incorporated to ensure ongoing compliance with program requirements. Views of Responsible Officials: Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe
Finding 2024-004 Reporting – Internal Control and Compliance Over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-23-MC-06-0555; B-22-MC-06-0555; B-20-MW-06-0555; B-19-MC-06-0555; B-18-MC-06-0555; B-17-MC-06-0555; B-16-MC-06-0555 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): PR29, CDBG and CDBG-CV Cash on Hand Quarterly Reports – PR29 in the Integrated Disbursement and Information System (IDIS) reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to the Department of Housing and Urban Development (“HUD”) on a quarterly basis, 30 days after the reporting period end date. The due date of each quarterly report is noted below: Reporting Period (End Date) Due Date of Reports September 30, 2023 October 30, 2023 December 31, 2023 January 30, 2024 March 31, 2024 April 30, 2024 June 30, 2024 July 30, 2024 Condition: During the audit, we noticed that three out of four quarters of PR29 for CDBG and CDBG-CV were not filed within the deadline, as shown below: Reporting Period Submission PR29 Report (End Date) Due Date of Reports Date CDBG September 30, 2023 October 30, 2023 November 6, 2023 CDBG March 31, 2024 April 30, 2024 May 1, 2024 CDBG June 30, 2024 July 30, 2024 September 18, 2024 CDBG-CV September 30, 2023 October 30, 2023 November 6, 2023 CDBG-CV March 31, 2024 April 30, 2024 May 1, 2024 CDBG-CV June 30, 2024 July 30, 2024 September 18, 2024 Cause: The City’s monitoring controls were inadequate to ensure the timely submission of the required reports. Effect or Potential Effect: The City was not in compliance with the programs’ reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-006. Recommendation: We recommend the City strengthen its internal controls over grant reporting by implementing a formal tracking system and assigning clear responsibility for the preparation and timely submission of the required reports. Regular review of reporting deadlines should be incorporated to ensure ongoing compliance with program requirements. Views of Responsible Officials: Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe
Finding 2024-004 Reporting – Internal Control and Compliance Over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-23-MC-06-0555; B-22-MC-06-0555; B-20-MW-06-0555; B-19-MC-06-0555; B-18-MC-06-0555; B-17-MC-06-0555; B-16-MC-06-0555 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): PR29, CDBG and CDBG-CV Cash on Hand Quarterly Reports – PR29 in the Integrated Disbursement and Information System (IDIS) reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to the Department of Housing and Urban Development (“HUD”) on a quarterly basis, 30 days after the reporting period end date. The due date of each quarterly report is noted below: Reporting Period (End Date) Due Date of Reports September 30, 2023 October 30, 2023 December 31, 2023 January 30, 2024 March 31, 2024 April 30, 2024 June 30, 2024 July 30, 2024 Condition: During the audit, we noticed that three out of four quarters of PR29 for CDBG and CDBG-CV were not filed within the deadline, as shown below: Reporting Period Submission PR29 Report (End Date) Due Date of Reports Date CDBG September 30, 2023 October 30, 2023 November 6, 2023 CDBG March 31, 2024 April 30, 2024 May 1, 2024 CDBG June 30, 2024 July 30, 2024 September 18, 2024 CDBG-CV September 30, 2023 October 30, 2023 November 6, 2023 CDBG-CV March 31, 2024 April 30, 2024 May 1, 2024 CDBG-CV June 30, 2024 July 30, 2024 September 18, 2024 Cause: The City’s monitoring controls were inadequate to ensure the timely submission of the required reports. Effect or Potential Effect: The City was not in compliance with the programs’ reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-006. Recommendation: We recommend the City strengthen its internal controls over grant reporting by implementing a formal tracking system and assigning clear responsibility for the preparation and timely submission of the required reports. Regular review of reporting deadlines should be incorporated to ensure ongoing compliance with program requirements. Views of Responsible Officials: Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe
Finding 2024-004 Reporting – Internal Control and Compliance Over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-23-MC-06-0555; B-22-MC-06-0555; B-20-MW-06-0555; B-19-MC-06-0555; B-18-MC-06-0555; B-17-MC-06-0555; B-16-MC-06-0555 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): PR29, CDBG and CDBG-CV Cash on Hand Quarterly Reports – PR29 in the Integrated Disbursement and Information System (IDIS) reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to the Department of Housing and Urban Development (“HUD”) on a quarterly basis, 30 days after the reporting period end date. The due date of each quarterly report is noted below: Reporting Period (End Date) Due Date of Reports September 30, 2023 October 30, 2023 December 31, 2023 January 30, 2024 March 31, 2024 April 30, 2024 June 30, 2024 July 30, 2024 Condition: During the audit, we noticed that three out of four quarters of PR29 for CDBG and CDBG-CV were not filed within the deadline, as shown below: Reporting Period Submission PR29 Report (End Date) Due Date of Reports Date CDBG September 30, 2023 October 30, 2023 November 6, 2023 CDBG March 31, 2024 April 30, 2024 May 1, 2024 CDBG June 30, 2024 July 30, 2024 September 18, 2024 CDBG-CV September 30, 2023 October 30, 2023 November 6, 2023 CDBG-CV March 31, 2024 April 30, 2024 May 1, 2024 CDBG-CV June 30, 2024 July 30, 2024 September 18, 2024 Cause: The City’s monitoring controls were inadequate to ensure the timely submission of the required reports. Effect or Potential Effect: The City was not in compliance with the programs’ reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-006. Recommendation: We recommend the City strengthen its internal controls over grant reporting by implementing a formal tracking system and assigning clear responsibility for the preparation and timely submission of the required reports. Regular review of reporting deadlines should be incorporated to ensure ongoing compliance with program requirements. Views of Responsible Officials: Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe
Finding 2024-004 Reporting – Internal Control and Compliance Over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-23-MC-06-0555; B-22-MC-06-0555; B-20-MW-06-0555; B-19-MC-06-0555; B-18-MC-06-0555; B-17-MC-06-0555; B-16-MC-06-0555 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): PR29, CDBG and CDBG-CV Cash on Hand Quarterly Reports – PR29 in the Integrated Disbursement and Information System (IDIS) reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to the Department of Housing and Urban Development (“HUD”) on a quarterly basis, 30 days after the reporting period end date. The due date of each quarterly report is noted below: Reporting Period (End Date) Due Date of Reports September 30, 2023 October 30, 2023 December 31, 2023 January 30, 2024 March 31, 2024 April 30, 2024 June 30, 2024 July 30, 2024 Condition: During the audit, we noticed that three out of four quarters of PR29 for CDBG and CDBG-CV were not filed within the deadline, as shown below: Reporting Period Submission PR29 Report (End Date) Due Date of Reports Date CDBG September 30, 2023 October 30, 2023 November 6, 2023 CDBG March 31, 2024 April 30, 2024 May 1, 2024 CDBG June 30, 2024 July 30, 2024 September 18, 2024 CDBG-CV September 30, 2023 October 30, 2023 November 6, 2023 CDBG-CV March 31, 2024 April 30, 2024 May 1, 2024 CDBG-CV June 30, 2024 July 30, 2024 September 18, 2024 Cause: The City’s monitoring controls were inadequate to ensure the timely submission of the required reports. Effect or Potential Effect: The City was not in compliance with the programs’ reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-006. Recommendation: We recommend the City strengthen its internal controls over grant reporting by implementing a formal tracking system and assigning clear responsibility for the preparation and timely submission of the required reports. Regular review of reporting deadlines should be incorporated to ensure ongoing compliance with program requirements. Views of Responsible Officials: Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe
Finding 2024-004 Reporting – Internal Control and Compliance Over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-23-MC-06-0555; B-22-MC-06-0555; B-20-MW-06-0555; B-19-MC-06-0555; B-18-MC-06-0555; B-17-MC-06-0555; B-16-MC-06-0555 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): PR29, CDBG and CDBG-CV Cash on Hand Quarterly Reports – PR29 in the Integrated Disbursement and Information System (IDIS) reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to the Department of Housing and Urban Development (“HUD”) on a quarterly basis, 30 days after the reporting period end date. The due date of each quarterly report is noted below: Reporting Period (End Date) Due Date of Reports September 30, 2023 October 30, 2023 December 31, 2023 January 30, 2024 March 31, 2024 April 30, 2024 June 30, 2024 July 30, 2024 Condition: During the audit, we noticed that three out of four quarters of PR29 for CDBG and CDBG-CV were not filed within the deadline, as shown below: Reporting Period Submission PR29 Report (End Date) Due Date of Reports Date CDBG September 30, 2023 October 30, 2023 November 6, 2023 CDBG March 31, 2024 April 30, 2024 May 1, 2024 CDBG June 30, 2024 July 30, 2024 September 18, 2024 CDBG-CV September 30, 2023 October 30, 2023 November 6, 2023 CDBG-CV March 31, 2024 April 30, 2024 May 1, 2024 CDBG-CV June 30, 2024 July 30, 2024 September 18, 2024 Cause: The City’s monitoring controls were inadequate to ensure the timely submission of the required reports. Effect or Potential Effect: The City was not in compliance with the programs’ reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-006. Recommendation: We recommend the City strengthen its internal controls over grant reporting by implementing a formal tracking system and assigning clear responsibility for the preparation and timely submission of the required reports. Regular review of reporting deadlines should be incorporated to ensure ongoing compliance with program requirements. Views of Responsible Officials: Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe
Finding 2024-004 Reporting – Internal Control and Compliance Over Reporting Identification of the Federal Program: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant/Entitlement Grants Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: N/A Federal Award Identification Number: B-23-MC-06-0555; B-22-MC-06-0555; B-20-MW-06-0555; B-19-MC-06-0555; B-18-MC-06-0555; B-17-MC-06-0555; B-16-MC-06-0555 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): PR29, CDBG and CDBG-CV Cash on Hand Quarterly Reports – PR29 in the Integrated Disbursement and Information System (IDIS) reports the financial status of the grants and cooperative agreement funds and cash transactions using those funds. These reports are required to be submitted to the Department of Housing and Urban Development (“HUD”) on a quarterly basis, 30 days after the reporting period end date. The due date of each quarterly report is noted below: Reporting Period (End Date) Due Date of Reports September 30, 2023 October 30, 2023 December 31, 2023 January 30, 2024 March 31, 2024 April 30, 2024 June 30, 2024 July 30, 2024 Condition: During the audit, we noticed that three out of four quarters of PR29 for CDBG and CDBG-CV were not filed within the deadline, as shown below: Reporting Period Submission PR29 Report (End Date) Due Date of Reports Date CDBG September 30, 2023 October 30, 2023 November 6, 2023 CDBG March 31, 2024 April 30, 2024 May 1, 2024 CDBG June 30, 2024 July 30, 2024 September 18, 2024 CDBG-CV September 30, 2023 October 30, 2023 November 6, 2023 CDBG-CV March 31, 2024 April 30, 2024 May 1, 2024 CDBG-CV June 30, 2024 July 30, 2024 September 18, 2024 Cause: The City’s monitoring controls were inadequate to ensure the timely submission of the required reports. Effect or Potential Effect: The City was not in compliance with the programs’ reporting requirements. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-006. Recommendation: We recommend the City strengthen its internal controls over grant reporting by implementing a formal tracking system and assigning clear responsibility for the preparation and timely submission of the required reports. Regular review of reporting deadlines should be incorporated to ensure ongoing compliance with program requirements. Views of Responsible Officials: Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe
Finding 2024-003 Internal Control Over Suspension and Debarment Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2021-075-00; CA-2023-202-00 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Prior to entering into subawards and contracts with award funds, recipients must ensure that contractors and subcontractors are not suspended from participating in federally funded projects. Verification is typically done by reviewing the System for Award Management (“SAM”) database and including certifications in contacts. Condition: During the audit, we noticed that the City did not perform suspension and debarment checks prior to awarding contracts. No evidence was available to show that vendors were verified against the System for Award Management (SAM) database or that suspension and debarment certifications were obtained. Cause: While the City adopted a suspension and debarment policy on April 2024, the policy was not in effect for a portion of the fiscal year and was not applied retroactively resulting in vendor verifications not being performed. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects prior to the contract being awarded, the City could be contracting with vendors that are prohibited from working on federally funded projects and incurring potentially disallowed costs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-005. Recommendation: We recommend the City ensure full implementation of its suspension and debarment policy adopted on April 2024, including applying verification procedures to all applicable federally funded contracts moving forward. Views of Responsible Officials: The City implemented a new review, tracking and documentation process for all procurements during FY 2023-24. Staff have been performing checks of all vendors -- regardless of the nature of the funding for the project – against SAM.GOV to check for disbarment. A PDF of the results for each vendor is saved in a project folder attached to each procurement. These files are stored on an internal network drive. Management feels the process in place addresses this finding.
Finding 2024-003 Internal Control Over Suspension and Debarment Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2021-075-00; CA-2023-202-00 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Prior to entering into subawards and contracts with award funds, recipients must ensure that contractors and subcontractors are not suspended from participating in federally funded projects. Verification is typically done by reviewing the System for Award Management (“SAM”) database and including certifications in contacts. Condition: During the audit, we noticed that the City did not perform suspension and debarment checks prior to awarding contracts. No evidence was available to show that vendors were verified against the System for Award Management (SAM) database or that suspension and debarment certifications were obtained. Cause: While the City adopted a suspension and debarment policy on April 2024, the policy was not in effect for a portion of the fiscal year and was not applied retroactively resulting in vendor verifications not being performed. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects prior to the contract being awarded, the City could be contracting with vendors that are prohibited from working on federally funded projects and incurring potentially disallowed costs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: 2023-005. Recommendation: We recommend the City ensure full implementation of its suspension and debarment policy adopted on April 2024, including applying verification procedures to all applicable federally funded contracts moving forward. Views of Responsible Officials: The City implemented a new review, tracking and documentation process for all procurements during FY 2023-24. Staff have been performing checks of all vendors -- regardless of the nature of the funding for the project – against SAM.GOV to check for disbarment. A PDF of the results for each vendor is saved in a project folder attached to each procurement. These files are stored on an internal network drive. Management feels the process in place addresses this finding.