Audit 372195

2024-002 Suspension and Debarment ALN 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Department of the Treasury Grant # Y5082 2021 funding Condition: City staff were unable to produce contemporaneous documentation of verification that vendors were not disqualified, excluded, or debarred prior to entering into a covered transaction. Criteria: 2 CFR 180.300 requires the City to ensure vendors and contractors are not disqualified, excluded, or debarred prior to entering into a covered transaction. 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The City should have a process to ensure compliance with 2 CFR 180.300. Cause: The City has experienced significant turnover in key management positions, including the City Manager and Finance Director, which created obstacles to locating documentation from prior periods. Potential Effect of Condition: Without a prior SAM check the City may have covered transactions with federally debarred vendors. However, in this case the impacted vendor was not debarred so there were no instances of non-compliance. Questioned Costs: None. Perspective: Of the non statistical sample of two vendors, one of the vendors did not have verification of not being suspended or debarred. Recommendation: The City should perform SAM checks for all vendors or contractors prior to entering into covered transactions and retain documentation of these processes. Management Response: Management concurs with the recommendation. The City recognizes the importance of complying with 2 CFR 180.300 and 2 CFR 200.303 to ensure that vendors and contractors are not suspended, debarred, or otherwise excluded from participation in federally funded programs. To strengthen compliance and documentation going forward, the City will implement the following corrective actions: 1. Establish a Standardized SAM Verification Process: The City will formalize written procedures requiring verification of all vendors and contractors in the System for Award Management (SAM) prior to entering into any covered transaction. 2. Maintain Documentation: Copies or screenshots of SAM verifications will be retained in the vendor file and/or attached within the City’s financial management system to ensure documentation is readily available for audit purposes. 3. Designate Responsibility: The Finance Department will assign a staff member to perform and document the SAM verification process, with supervisory review prior to vendor approval. 4. Provide Staff Training: Relevant staff will receive training on federal procurement requirements, including SAM verification procedures and documentation standards. 5. Ongoing Monitoring: Management will periodically review vendor files to confirm compliance with these requirements and ensure documentation is properly maintained. Management expects these measures will strengthen internal controls, ensure continued compliance with federal regulations, and prevent similar documentation issues in future audits.