Audit 391617

Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus Relief Fund Assistance Listing Number: 21.019 Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency over Compliance and Other Matters Criteria or specific requirement: 2 CFR 200.303 requires non-federal entities to establish and maintain internal control designed to reasonably ensure compliance with federal statutes and regulations, including procedures to verify and document vendor eligibility. 2 CFR 200.214 requires verification that vendors are not suspended or debarred prior to entering into covered transactions. Condition: The City does not have a documented control to perform and retain evidence of suspension and debarment verification (e.g., SAM.gov check or vendor certification) at the time of entering into covered transactions funded by federal awards. Management indicated that vendor eligibility checks are performed as part of standard operating practice; however, documentation evidencing the timing and performance of these checks was not retained. Questioned costs: None. Context: Four of the five covered transactions selected did not have proper supporting documentation for suspension and debarment procedures. Cause: For three of the transactions tested, the City relied on cooperative purchasing agreements. Accordingly, the City did not perform or retain documentation of its own suspension and debarment verification. For the remaining transaction, documentation evidencing suspension and debarment compliance was not retained. Effect: The City did not have a documented control to perform and retain evidence of suspension and debarment verification at the time of award, as required by 2 CFR 200.303. Repeat Finding: No. Recommendation: We recommend the City obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM.gov. Views of responsible officials: There is no disagreement with the audit finding.