Suspension and Debarment
Benton County has established internal controls to verify all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs. Internal practice now requires that all contracts be reviewe...
Suspension and Debarment
Benton County has established internal controls to verify all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs. Internal practice now requires that all contracts be reviewed by the purchasing department to ensure they meet the requirements of state and federal regulations. The bid proposal documents also now contain a form, to be completed by each bidder, certifying that they are not suspended or debarred from receiving federal funds. These steps where implemented as a result of a finding from our 2021 Audit that was issued in March 2023 by the State Auditors Office. Unfortunately this non-compliance occurred in April 2022 so the new internal practice had not been implemented as we did not become aware of the deficiency until March 2023.
Additionally, for the SLFRF program and other coronavirus relief funds a “double check” by the grant/finance manager has been implemented to verify the debarment status of contractors who may be paid with those funds. The County has established internal control practices to verify that all contractors awarded a contract that is paid all or in part with federal funds are not suspended or debarred from receiving such funds. The prospective contractors status is verified using SAM.gov, and the verification is documented in the project file, prior to execution of a contract. Our bidding documents also now contain a form on which the contractor must also certify that they are not suspended or debarred.
Subrecipient Monitoring
Benton County has implemented an internal practice that all contracts must be reviewed by the purchasing department to ensure compliance with state and federal regulations. This review will also ensure that all required contract elements are included, and that particular attention is drawn to notify contractors that the contract is paid all or in part with federal funds.
While the County did perform a risk assessment in accordance with Treasury guidance these were not well documented. The County has developed a template risk assessment form to be included in the bidding documents for contracts funded all or in part with federal funds.
The County does monitor subrecipient expenditures by requesting, and reviewing, detailed invoices for any payments made to sub recipients. The County also requires monthly written reports from sub recipients and our contract language also reserves the right for the County to review and audit all sub recipient financial information. Depending on the nature of the contract routine meetings with sub recipients are also held to monitor progress and discuss and resolve areas of concern. Inspection of documents and regular contact with sub recipients is part of our normal contracting process.
The County is developing a draft risk assessment policy that includes a formal assessment template that will be modifiable per specific conditions of revised future guidance from federal or state grantors.