CITY OF GOSHEN CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (SLRF) – Suspension and Debarment Contact Person Responsible for Corrective Action: Goshen Clerk-Treasurer Richard R. Aguirre Contact Phone Number and Email address: 5...
CITY OF GOSHEN CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (SLRF) – Suspension and Debarment Contact Person Responsible for Corrective Action: Goshen Clerk-Treasurer Richard R. Aguirre Contact Phone Number and Email address: 574-533-8623; richardaguirre@goshencity.com Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: For future expenditures involving federal programs, and prior to entering into covered transactions, the City of Goshen will verify that all contractors and subrecipients are not suspended or debarred or otherwise excluded by using one or more of the following procedures: (a) incorporating the required suspension and debarment language into fully executed agreements, (b) obtaining written or emailed certification from vendors confirming they are neither suspended nor debarred, (c) verifying vendor status through the applicable federal suspension and debarment database (Excluded Parties List System, EPLS). The City has included suspension and debarment clauses in many contracts involving the use of federal and state monies since 2023. However, due to an internal misunderstanding within another City Department, the agreement at issue was not identified as being subject to the federal suspension and debarment requirement. That is because, in April 2024, the City awarded a contract to a local contractor for the Steury Avenue and Lincoln Avenue Reconstruction and Drainage Improvement project and the Goshen Common Council did not approve using $5,086,932.81 in American Rescue Plan funds (SLRF) for that project until Dec. 16, 2024. So, there was no verification before the expenditure of $1,875,887 of SLRF funds for the contractor in 2025. As of the date of this corrective action plan, the Clerk-Treasurer’s Office has verified that contractors and vendors paid with federal funds in 2025 and 2026 (including the contractor identified in Finding 2025-002) are not suspended or debarred or otherwise excluded. Going forward, the Clerk-Treasurer’s Office and the Grant Coordinator will coordinate more closely with all City departments to improve awareness of the suspension and debarment compliance requirements associated with federal awards. This enhanced communication and oversight is intended to prevent similar instances of noncompliance in the future. Anticipated Completion Date: City officials and key staff members have been reminded of these verification procedures through verbal communication, email, or both. By Dec. 31, 2026, City staff will receive additional guidance from Clerk- Treasurer’s staff on identifying when suspension and debarment requirements apply to vendor contracts and on following the City's established verification procedures before contract approval and execution. – Completed and resubmitted to the State Board of Accounts, August 10, 2026