FINDING 2023-001
Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment
Summary of Finding: Evidence was not retained showing vendors were checked for suspension and
debarment.
Contact Person Responsible for Corrective Action: Valeriano Gomez, City Controller
C...
FINDING 2023-001
Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment
Summary of Finding: Evidence was not retained showing vendors were checked for suspension and
debarment.
Contact Person Responsible for Corrective Action: Valeriano Gomez, City Controller
Contact Phone Number and Email Address: (219) 391-8220 vgomez@eastchicago.com
Views of Responsible Officials: We concur with the finding
Description of Corrective Action Plan: Engineering Department in prior audit (2022‐001) verified that
two vendors were not suspended or debarred by checking SAM exclusions; but did not retain the
documentation, nor was a policy to ensure future internal control & compliance effectively put in place.
The following actions will be put in place to address these issues:
1. Engineering Department has contacted the firms involved in prior audit to provide certifications
and update the contracts pertaining to the suspension and debarment documentation /
certifications for verification.
2. The City of East Chicago, will enact the following policy into the City’s purchasing Policy, through
passage by the Board of Public Works Resolution, to be followed by similar resolutions by all City
Department Boards:
CITY OF EAST CHICAGO SUSPENSION / OR DEBARMENT POLICY FOR VENDOR WHEN FEDERAL FUNDS /
ASSISTANCE INVOLVED:
The following specific provisions to be followed under the City of East Chicago purchasing policy and
procedure for determining Suspension and Debarment status of any vendor doing business with the City
for which federal funds and / or federal assistance are to be utilized by City.
A. SAM search, verification by contracted vendor or contractual provision. Prior to any purchase
for which federal funds or federal assistance is to be utilized by the City, the purchasing agency,
or its designee, shall:
1. Examine and verify the status of any vendor participating in or to be contracting for
business with the City utilizing federal funds and or federal assistance for debarment and
suspension status to determine whether the vendor is qualified to participate. The check or
Anthony Copeland
Mayor
verification for debarment and suspension shall be performed using the System for Award
Management (SAM) or any similar system currently approved for such purpose. The City
Departments / Boards responsible for facilitating, coordinating and utilizing federal funds
will be required to conduct and complete the SAM search, or its approved equivalent, as
such procedures and methods are amended, on all vendors with whom the City intends to
conduct business utilizing federal funds. Further the City or entity responsible shall provide a
hard copy proof and verification of each SAM search for record keeping.
2. Require each contracted vendor utilizing federal funds to certify that the contracted vendor
was not suspended or debarred; or
3. Add a clause to appropriate contract to ensure that the contracted vendors were not
suspended or debarred.
4. Further these policy requirements for determination of suspension and / or debarment
status of any vendor doing business with the City of East Chicago, in which federal funds and
/ or federal assistance are utilized shall pertain to “Covered Transactions” under 2 C.F. R. pt.
180, subpt. B which include those government 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 specified criteria.
B. No business with a debarred or suspended entity. It is specifically directed and required that the
City of East Chicago, shall not conduct any business with any firm, individual, or entity that has
been identified as having been debarred or suspended for such purposes, in conformance with
applicable law; in particular, 2CFR 180.300
a. 2 CFR 180.300 states: When you enter into a covered transaction with another person at
the next lower tier, you must verify that the person with whom you intend to do business is
not excluded or disqualified. You must do this by: 1. Checking SAM Exclusions; or 2.
Collecting a certification from that person; or 3. Adding a clause or condition to the covered
transaction with that person.
Anticipated Completion Date: 01/01/2025