Audit 410914

Procurement Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus Capital Projects Fund (CCPF) Assistance Listing Number: 21.029 Federal Award Identification Number and Year: NOW-20005 - 2025 Pass-Through Agency: Rhode Island Department of the Treasury Pass-Through Number: NOW-20005 Award Period: August 2, 2023 – October 30, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Repeat Finding: No Criteria or specific requirement: Per Uniform Guidance §200.318 General procurement standards, a non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition: The Town of Smithfield does not have a written conflict of interest policy in place for the selection, award, and administration of contracts as required by Uniform Guidance. Questioned Costs: None Context: Although the Town does not have a written conflict of interest policy in place for the selection, award, and administration of contracts, we did not identify transactions where contracts were awarded where there appeared to be a conflict of interest in the procurement process in 3 of 3 procurement transactions tested. Cause: Management was not aware of the procurement standards set out at 2 CFR section §200.318 within Uniform Guidance. Effect: The Town is at risk for noncompliance with Federal grants as it relates to procurement. Recommendation: We recommend the Town implement a written conflict of interest policy in line with Uniform Guidance §200.318. Views of Responsible Officials: Management agrees with this finding.

Suspension and Debarment Federal Agency: U.S. Department of the Treasury Federal Programs: Coronavirus Capital Projects Fund (CCPF) Assistance Listing Number: 21.029 Federal Award Identification Number and Year: NOW-20005 - 2025 Pass-Through Agency: Rhode Island Department of Treasury Pass-Through Number: NOW-20005 Award Period: August 2, 2023 – October 30, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Repeat Finding: No Criteria or specific requirement: Recipients and subrecipients are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, or debarred. “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 section 180.220. When a recipient or subrecipient enters into a covered transaction with an entity at a lower tier, the recipient or subrecipient must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing we identified that the Town failed to maintain documentation of procedures performed to determine that a vendor was not suspended or debarred prior to the signing of the contract for one of three transactions tested. Questioned Costs: None Context: Although the Town failed to maintain documentation for one vendor regarding procedures performed to determine they were not suspended or debarred prior to the signing of the contract, we did not note any transactions where federal grant awards were paid to suspended or debarred vendors. Cause: The planning department performed a search for the vendor through SAM.gov but failed to maintain documentation of the search. Effect: The Town is at risk for noncompliance with federal grants as it relates to suspension and debarment. Recommendation: We recommend the Town update internal control policies and procedures to ensure that suspension and debarment procedures are performed, and written documentation is retained prior to the approval of contracts involving federal awards. Views of Responsible Officials: Management agrees with this finding.