Audit 391401

Condition: The County did not maintain documentation demonstrating that vendors were verified as not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into a covered transaction. While procurement documentation was maintained for the related purchase, evidence of suspension and debarment verification was not included in the procurement file. Criteria: Non-federal entities are required to ensure that contracts and covered transactions are not awarded to parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Federal procurement standards require entities to maintain oversight and procedures to verify contractor eligibility and responsibility, including compliance with suspension and debarment requirements, in accordance with 2 CFR 200.212 and 200.318(h), 2 CFR 180.300, and 48 CFR 52.209-6. Cause: The County’s procurement procedures did not require documented verification of vendor suspension and debarment status prior to entering into covered transactions. Effect: Failure to document suspension and debarment verification increases the risk that the County could enter into agreements with ineligible vendors, resulting in noncompliance with federal procurement requirements. Recommendation: We recommend the County implement procedures requiring documented verification that vendors are not suspended, debarred, or otherwise excluded prior to entering into covered transactions and retain such documentation within the procurement file, in accordance with 2 CFR 200.212 and 200.318(h), 2 CFR 180.300, and 48 CFR 52.209-6.