Audit 395494

SA2025-001: Suspension and Debarment Verification Not Documented – Significant Deficiency Assistance Listing Numbers: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: U.S. Department of Treasury Federal Award Identification Number: N/A Criteria Per 2 CFR section 180.300, 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition During testing of procurement transactions, we noted that debarment and suspension verification was not documented for one of the two procurements tested. Cause The City did not maintain sufficient documentation to demonstrate that the required debarment and suspension verification was performed prior to entering into the transaction. Effect Inability to demonstrate compliance with debarment and suspension requirements may result in questioned costs requiring repayment to federal agencies if the City enters into covered transactions with vendors that are subsequently identified as either suspended or debarred from participating in federally funded programs. Questioned Costs No questioned costs were identified. Recommendation We recommend that the City enhance its procedures to ensure that suspension and debarment verification is performed prior to contract award and that appropriate documentation is retained in the procurement file to support compliance with federal requirements. Management Response The City concurs with the finding. The required suspension and debarment verification was completed; however, the documentation retained did not meet federal standards. The City is currently updating procedures city-wide to ensure full SAM.gov documentation is retained and that suspension/debarment contract language is consistently applied.