Audit 4349

Reference # and title: 2022-004 Suspension and Debarment Federal Grantor/Program Name Assistance Listing No. Award Year United States Department of Treasury Coronavirus State and Local Fiscal Recovery Funds 21.027 2022 Criteria or specific requirement: Non-Federal entities 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 non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition found: In testing compliance and internal controls with respect to the Uniform Guidance 2 CFR section 180.300, the Police Jury did not properly verify that the vendor was not excluded or debarred before contracting with the vendor. Additionally, no such clause or representation was included in the signed contract or purchase order certifying that the vendor was not suspended, debarred, or otherwise excluded from participating in the covered transaction. Our audit procedures did not identify any covered transactions that equaled or exceeded $25,000 with vendors suspended, debarred, or otherwise excluded from providing services under the program. Context: The Police Jury did not verify covered transactions with SAM, collect a certification from the entity, or add a clause or condition to covered transactions exceeding $25,000. Possible asserted effect (cause and effect): Cause: The Police Jury does not have policy and procedures requiring verification or certification that the vendor in which it expects to expend $25,000 or more has not been suspended, debarred, or otherwise excluded from participating in the transaction. Effect: Without vendor verification or certification, the Police Jury may potentially enter into contracts/transactions with suspended, debarred, or otherwise excluded vendors. Recommendation to prevent future occurrences: The Police Jury should implement policies and procedures requiring verification or certification that a vendor, with which it plans to expend $25,000 or more has not been suspended, debarred, or otherwise excluded from participating in the transaction by adding a clause or condition to all contracts or purchase orders. Origination date and prior year reference (if applicable): This finding originated in the fiscal year ended December 31, 2021. View of responsible official: I concur with the recommendation.

Reference # and title: 2022-004 Suspension and Debarment Federal Grantor/Program Name Assistance Listing No. Award Year United States Department of Treasury Coronavirus State and Local Fiscal Recovery Funds 21.027 2022 Criteria or specific requirement: Non-Federal entities 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 non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition found: In testing compliance and internal controls with respect to the Uniform Guidance 2 CFR section 180.300, the Police Jury did not properly verify that the vendor was not excluded or debarred before contracting with the vendor. Additionally, no such clause or representation was included in the signed contract or purchase order certifying that the vendor was not suspended, debarred, or otherwise excluded from participating in the covered transaction. Our audit procedures did not identify any covered transactions that equaled or exceeded $25,000 with vendors suspended, debarred, or otherwise excluded from providing services under the program. Context: The Police Jury did not verify covered transactions with SAM, collect a certification from the entity, or add a clause or condition to covered transactions exceeding $25,000. Possible asserted effect (cause and effect): Cause: The Police Jury does not have policy and procedures requiring verification or certification that the vendor in which it expects to expend $25,000 or more has not been suspended, debarred, or otherwise excluded from participating in the transaction. Effect: Without vendor verification or certification, the Police Jury may potentially enter into contracts/transactions with suspended, debarred, or otherwise excluded vendors. Recommendation to prevent future occurrences: The Police Jury should implement policies and procedures requiring verification or certification that a vendor, with which it plans to expend $25,000 or more has not been suspended, debarred, or otherwise excluded from participating in the transaction by adding a clause or condition to all contracts or purchase orders. Origination date and prior year reference (if applicable): This finding originated in the fiscal year ended December 31, 2021. View of responsible official: I concur with the recommendation.