FINDING 2024-001
Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - 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 Offici...
FINDING 2024-001
Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - 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: A Suspension and Debarment policy was adopted at the
conclusion of the 2023 audit, however, the policy was not presented to and officially adopted by the East
Chicago Board of Works until the August 22, 2024, meeting. This oversight resulted in a delay of the
anticipated enactment of the policy resulting in there being sufficient time to enact the new policy for the
current audit year of 2024. The current summary schedule of prior audit findings reflects the issue as
partially corrected, providing the supporting documents consisting of Board of Works actions in regard to
the policy. Going forward, all steps are in place for correction of the situation. See policy below.
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 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. 8 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: Corrective action is now in effect as of August 18, 2025.