Federal Program Name: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
(CSLFRF Program)– Assistance Listing No. 21.027
Compliance Requirement: Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Recommendation: We recommend ...
Federal Program Name: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
(CSLFRF Program)– Assistance Listing No. 21.027
Compliance Requirement: Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Recommendation: We recommend that the City incorporate specific language into its
existing procurement process—particularly regarding suspension and debarment
requirements—by clearly assigning responsibility for conducting these checks to the
agency receiving and overseeing the federal award, both prior to any federal spending and
on a recurring basis thereafter.
Explanation of disagreement with audit finding: There is no disagreement with the audit
finding.
Action taken in response to finding:
Procedure Enhancement: The Department of Finance’s Grant Operations team will
develop and publish a more detailed procedure and FAQ outlining the process for
conducting suspension and debarment checks in compliance with federal requirements.
This will include clear guidance on:
o The timing (prior to execution and upon renewal or amendment)
o The verification method (e.g., SAM.gov),
o Required documentation standards for these checks (attaching with the contract
or purchase order in Workday, the City’s financial system of record)
Clarification of Roles and Responsibilities: The updated procedure will explicitly address
multi-agency procurements. It will specify that the agency receiving and managing the
federal funding is responsible for completing and documenting the suspension and
debarment check, regardless of which agency initiates or supports the procurement
process.
Training and Communication: The Department of Finance and will communicate these
updates through:
o Direct outreach to agencies where the finding was made
o Regular Grant Policy Advisory Committee (GPAC) meetings
o Updated training materials for agency grant leads/liaisons
Name(s) of the contact person(s) responsible for corrective action: Justin Sykes, Budget
and Management Director; Toni Bellucci, Citywide Grants Manager
Planned completion date for corrective action plan: August 30, 2025