Audit 385925

Criteria: 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. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR 180.220. This requirement applies to contracts and purchases entered into to procure goods and services with Coronavirus State and Local Fiscal Recovery Funds. Condition: The Town of North Smithfield does not have a specific procedure in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. Cause: The Town has not established suspension and debarment policies and procedures for federal awards. Effect: Contracts for goods and service that were “covered transactions” were entered into prior to verifying that an entity was not suspended, debarred, or otherwise excluded. Questioned Costs: None Recommendation: We recommend that the Town implement verification procedures to ensure that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. Views of Responsible Officials and Corrective Action: For any bids that intend to use federal funding through its award and execution, the Town will use a suspension and debarment certification that will require the bidder’s signature, as well as verifying the awarded bidder through SAM.gov. Any other purchases made by the Town using federal funds will require the vendor to be verified through SAM.gov. Anticipated Completion Date: This policy with be in effect immediately. Contact Person: Antony St. Onge, Purchasing Agent