Audit 385708

Significant Deficiency in Internal Control over Compliance 2025-003 Procurement, Suspension and Debarment Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing No: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Identification: ARPA-1087 Grant Year: 2023 Applicable Pass-through Entity: Wyoming Office of State Lands and Investments Criteria Uniform Guidance requires non-federal entities to perform procurement procedures that provide for full and open competition and comply with applicable federal, state, and local laws and regulations. In addition, 2 CFR §180 and §200.213 require non-federal entities to ensure that vendors receiving federal funds are not suspended or debarred, and to have procedures in place to verify vendor eligibility prior to contract award. Condition Non-federal entities should follow procurement procedures and retain documentation to verify that vendors were not suspended or debarred prior to entering into a covered transaction for contracts or making payments using federal funds. Cause The County lacks documentation to verify that vendors were not suspended or debarred prior to entering into a covered transaction for contracts or making payments using federal funds. Effect or Potential Effect Without formal documentation of procurement policies followed regarding suspension and debarment, the County is at increased risk of noncompliance with federal regulations. This increases the likelihood of potential contracting with ineligible vendors. Continued noncompliance could result in audit findings, required repayment of federal funds, or other sanctions from grantor agencies. Questioned Costs None identified. Context Of three covered transactions tested, the County did not have formal documentation for two covered transactions showing they were not with vendors considered suspended or debarred. This formal documentation can take the form of certification from the vendor, a clause included in the contract, or formal SAM search performed and retained in the procurement documents. Identification as a Repeat Finding This is not a repeat finding Recommendation We recommend that management adhere to written procurement policies and procedures in accordance with Uniform Guidance requirements. These policies include procedures to verify and document vendor suspension and debarment status prior to contract award and periodically thereafter, such as through SAM.gov verification. Views of Responsible Officials Management agrees with the finding and plans to adhere to compliance with suspension and debarment policies including documentation requirements. Implementation is expected to occur during the next fiscal year. See Corrective Action Plan