Audit 404663

FINDING: 2025-002 Clean Water State Revolving Fund - Suspension and Debarment U.S. Environmental Protection Agency, Passed through Pennsylvania Infrastructure Investment Authority (PENNVEST) – Assistance Lising Number 66.458 Statement of Condition: The Township did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Township did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Criteria: In accordance with 2 CFR Part 200.303, a non-Federal entity must establish and maintain effective internal control over Federal awards that provide reasonable assurance that the non-Federal entity manages the Federal award in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause: The Township did not follow the internal control procedures to document the review of the SAM.gov exclusion list prior to contract execution. Effect: The lack of following internal control procedures to review the verification of suspension and debarment prior to entering into contracts, agreements, and grants, could result in the Township entering into covered transactions with entities that are suspended and debarred which is not allowed under the Clean Water State Revolving Fund program. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Township should follow the internal control procedure of reviewing the suspension and debarment verification prior to entering into contracts, agreements and grants. The review should be documented. Views of responsible officials and planned corrective action: Management agrees with the finding. See separate corrective action plan.