Audit 414996

Finding 2023-004 Significant Deficiency – Suspension and Debarment Criteria: Per 2 CFR 200.212, 2 CFR 180.300, 2 CFR 200.318(h), and 48 CFR 52.209-6, the Town is required toverify that entities receiving covered contracts are not suspended, debarred, or otherwise excluded from participation in federal programs prior to award. Condition: The Town could not provide evidence that suspension and debarment verification was performed prior to contract award. The audit team independently verified the vendor's status through FAC.gov and noted no suspension or debarment concerns; however, documentation demonstrating that the Town performed this verification before awarding the contract was not available. Effect: Because the vendor was subsequently verified by the audit team as eligible, no known cost questioned were identified. However, the lack of documented verification increases the risk of contracting with an ineligible vendor and noncompliance with federal procurement requirements. Cause: Management did not maintain documentation evidencing that suspension and debarment verification procedures were performed and reviewed prior to contract execution. Recommendation: The Town should implement procedures requiring suspension and debarment verification prior to contract award and retain evidence of the verification in the procurement file to demonstrate compliance with federal requirements. Management Response: Management agrees with the finding and is implementing procedures to correct this, which is further discussed in the corrective action plan.