Finding 2023-002: Procurement, Suspension, and Debarment (Material Weakness) Federal Program: Assistance Listing Number 14.267 Criterion or Specific Requirements: 2 CFR Section 200.318 requires that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. 2 CFR Section 200.214 requires that, for covered transactions, a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded. This verification may be accomplished by checking the System for Award Management (SAM) website maintained by the General Services Administration. Condition: IW has a formal written procurement policy, but it does not conform to the procurement standards identified in §§ 200.317 through 200.327, which is the Uniform Guidance. As a result, no procurement files were maintained to document IW's procurement actions. In addition, for all disbursements tested, IW could not provide documentation of their verification, prior to payment, that the vendors were not suspended, debarred or otherwise excluded. Questioned Costs: None. Cause: IW has not updated its written procurement policy to conform to the Uniform Guidance. In addition, IW did not require that evidence of SAM checks be maintained in its vendor files. As a result, IW did not maintain adequate support to provide evidence that appropriate suspension and debarment searches were performed. Despite the lack of documentation, a search was performed after the fact to verify that the vendors or individuals in our sample were not suspended, debarred or otherwise excluded. Therefore, no questioned costs have been reported related to the sample that was tested. Effect or Potential Effect: Without an updated procurement policy that conforms to the Uniform Guidance and related procurement documentation, there is a risk that IW did not perform a proper evaluation of each potential vendor whose costs were charged to Federal programs. In addition, IW could not readily provide evidence that it had assessed whether or not its vendors were suspended, debarred, or otherwise excluded. As a result, the potential for payments to suspended, debarred, or otherwise excluded vendors and individuals exists. Recommendation: IW should revise its procurement policy so that it conforms to the Uniform Guidance. Furthermore, IW should maintain documentation in its files to provide evidence to support that it followed the procurement policy. In addition, IW should establish internal controls to ensure documentation is maintained to evidence that it performed the required suspension and debarment searches on the SAM website.
Finding 2023-003 21.027 – Coronavirus State and Local Fiscal Recovery Funds Noncompliance with Procurement Suspension and Debarment Criteria: 2 CFR Part 200.214 indicates “the regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities”. Condition: The County did not maintain documentation or have appropriate processes and procedures in place to ensure that prior to awarding contracts to outside parties the suspended or debarred list was checked to ensure the potential awardee was not prohibited from receiving federal funds. Cause: The County did not have policies and procedures in place to ensure the suspended and debarred list was checked consistently nor did they retain documentation of the list being checked prior to contracts being awarded to awardees. Effect: The County could award contracts to suspended or debarred parties. Questioned Costs: $149,370 Recommendations: We recommend the County implement processes and procedures to ensure the suspended and debarred listing is checked prior to awarding contracts to outside parties. In addition, we recommend the County maintain documentation of this check being performed. Views of responsible officials: Hood River County is training personnel to check Sam.gov for debarment of vendors prior to contract negotiation. A second check point is when vendors are set up in the Finance department Accounts Payable system. Currently there are no Hood River County vendors who have been on the Federal debarment list.
Finding 2023-003 21.027 – Coronavirus State and Local Fiscal Recovery Funds Noncompliance with Procurement Suspension and Debarment Criteria: 2 CFR Part 200.214 indicates “the regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities”. Condition: The County did not maintain documentation or have appropriate processes and procedures in place to ensure that prior to awarding contracts to outside parties the suspended or debarred list was checked to ensure the potential awardee was not prohibited from receiving federal funds. Cause: The County did not have policies and procedures in place to ensure the suspended and debarred list was checked consistently nor did they retain documentation of the list being checked prior to contracts being awarded to awardees. Effect: The County could award contracts to suspended or debarred parties. Questioned Costs: $149,370 Recommendations: We recommend the County implement processes and procedures to ensure the suspended and debarred listing is checked prior to awarding contracts to outside parties. In addition, we recommend the County maintain documentation of this check being performed. Views of responsible officials: Hood River County is training personnel to check Sam.gov for debarment of vendors prior to contract negotiation. A second check point is when vendors are set up in the Finance department Accounts Payable system. Currently there are no Hood River County vendors who have been on the Federal debarment list.
Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not available. Pass-Through Agencies: Massachusetts Department of Administration and Finance; Bristol County Pass-Through Number(s): Not Available Award Period: March 3, 2021 through December 31, 2026 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Title 2 of the U.S. Code of Federal Regulations (CFR), Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The Town did not obtain evidence supporting their verification that entities were not suspended, debarred, or otherwise excluded from participating in the grant award transactions. Questioned costs: None. Context: The Town did not obtain evidence of verification of the suspension and debarment status for three (3) of four (4) entities to which the Town incurred expenditures in excess of $25,000. Cause: Internal controls were not implemented to ensure documented evidence was obtained regarding the suspension and debarment status for all entities receiving federal funds in excess of $25,000 from the Town. Effect: The Town’s risk of noncompliance with the federal award program was elevated. It was later verified the entities in question were not suspended or debarred. Repeat Finding: No. Recommendation: We recommend the Town ensure documentation be obtained supporting the suspension and debarment status of entities to which the Town expends greater than $25,000. Such documentation could include (1) a history of searching SAM.gov exclusions, (2) certification from the entity, or (3) a clause or condition included in the contract or subaward with the entity. Views of Responsible Officials: There is no disagreement with the audit finding.
2023-002 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553 & 10.555 COVID-19 – Child Nutrition Cluster – ALN 10.555 Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Cause: The School experienced turnover during the year and could not locate the appropriate files. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-001. Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553 & 10.555 COVID-19 – Child Nutrition Cluster – ALN 10.555 Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Cause: The School experienced turnover during the year and could not locate the appropriate files. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-001. Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553 & 10.555 COVID-19 – Child Nutrition Cluster – ALN 10.555 Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Cause: The School experienced turnover during the year and could not locate the appropriate files. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-001. Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553 & 10.555 COVID-19 – Child Nutrition Cluster – ALN 10.555 Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Cause: The School experienced turnover during the year and could not locate the appropriate files. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-001. Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education SPED Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – SPED Cluster (IDEA) – ALN 84.027X Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Documentation of the solicitation of quotes for one purchase totaling $16,700 could not be found in Department files. Also, a written determination related to a sole source procurement totaling $15,460 was not in the Department files. Cause: The School does not have proper internal controls to ensure all procurements are properly documented. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education SPED Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – SPED Cluster (IDEA) – ALN 84.027X Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Documentation of the solicitation of quotes for one purchase totaling $16,700 could not be found in Department files. Also, a written determination related to a sole source procurement totaling $15,460 was not in the Department files. Cause: The School does not have proper internal controls to ensure all procurements are properly documented. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education SPED Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – SPED Cluster (IDEA) – ALN 84.027X Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Documentation of the solicitation of quotes for one purchase totaling $16,700 could not be found in Department files. Also, a written determination related to a sole source procurement totaling $15,460 was not in the Department files. Cause: The School does not have proper internal controls to ensure all procurements are properly documented. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education SPED Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – SPED Cluster (IDEA) – ALN 84.027X Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Documentation of the solicitation of quotes for one purchase totaling $16,700 could not be found in Department files. Also, a written determination related to a sole source procurement totaling $15,460 was not in the Department files. Cause: The School does not have proper internal controls to ensure all procurements are properly documented. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education SPED Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – SPED Cluster (IDEA) – ALN 84.027X Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Documentation of the solicitation of quotes for one purchase totaling $16,700 could not be found in Department files. Also, a written determination related to a sole source procurement totaling $15,460 was not in the Department files. Cause: The School does not have proper internal controls to ensure all procurements are properly documented. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education SPED Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – SPED Cluster (IDEA) – ALN 84.027X Significant Deficiency in Internal Controls Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Documentation of the solicitation of quotes for one purchase totaling $16,700 could not be found in Department files. Also, a written determination related to a sole source procurement totaling $15,460 was not in the Department files. Cause: The School does not have proper internal controls to ensure all procurements are properly documented. Effect: The District is not in compliance with Federal procurement, suspension and debarment requirements. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to maintain documentation of all procurement procedures including bidding and suspension and debarment compliance. Views of Responsible Official: Management agrees with the finding.
Type of Finding: Material Weakness in Internal Control over Compliance and Significant Deficiency over Compliance Condition: None of the five samples selected for testing had appropriate suspension and debarment checks prior to entering into the subawards. Criteria or specific requirement: § 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Effect: Without proper controls the Organization could enter award subrecipients with entities that are suspended or debarred. Cause: The Organization was unaware of the requirement to perform suspension and debarment checks on subrecipients. Recommendation: The Organization should Implement policies and procedures for performing suspension and debarment checks for all covered transactions, including subrecipients. Repeat Finding?: No Questioned Costs: None
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster (IDEA) – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for six covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster (IDEA) – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for six covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster (IDEA) – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for six covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster (IDEA) – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for six covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster (IDEA) – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for six covered transactions. Cause: Lack of appropriate oversight resulted in required suspension and debarment checks not being performed. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. It was determined that none of the three vendors were suspended or debarred from federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-004 – Procurement, Suspension and Debarment Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023 Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.
2023-004 – Procurement, Suspension and Debarment Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023 Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.
2023-004 – Procurement, Suspension and Debarment Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023 Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.
2023-004 – Procurement, Suspension and Debarment Federal agency: U.S. Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Champaign, Illinois; Champaign County, Illinois; Illinois Criminal Justice Information Authority Pass-Through Number(s): 20220246 - 2023; 20220245 - 2023; 822007 - 2023 Award Period: 3/1/22-12/31/23; 3/1/22-12/31/23; 3/1/22-12/31/24; 4/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: CFR § 200.320 indicates the various methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and § 200.317, 200.318, and 200.319 for any of the approved procurement methods used for the acquisition of property or services required under a Federal award or sub-award. § 200.214 Suspension and debarment indicates non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Organization did not have a procurement policy or suspension and debarment policy in place which was consistent with the requirements of the Uniform Guidance. As a result, the Organization could not provide supporting documentation showing that engaged vendors had gone through an appropriate procurement process. Questioned costs: N/A Context: 5 of 5 vendors selected for procurement testing, did not have documentation showing that the cost had been procured in accordance with the Uniform Guidance. Additionally, 2 of 2 vendors selected for testing suspension and debarment, did not have documentation showing that suspension and debarment had been checked prior to entering into a contract. Cause: Error by management in understanding Uniform Guidance requirements. Effect: Lack of appropriate procurement, suspension and debarment policies could result in the Organization engaging vendors who are debarred from doing business with the United States Government and/or using federal funds in manner that is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the Organization revised its internal controls related to procurement, suspension and debarment such that they align with the requirements of the Uniform Guidance. Views of responsible officials: The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.
CONDITION: In connection with the Cambria Heights School District’s RTU Replacement Project, the District did not perform debarment and suspension checks for contractors through SAM.gov. This is a repeat finding (2022-009) from the previous fiscal year. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Cambria Heights School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: Hranec Sheet Metal, Inc. - $1,058,759, Westmoreland Electric Services – $92,163. RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: In connection with the Cambria Heights School District’s RTU Replacement Project, the District did not perform debarment and suspension checks for contractors through SAM.gov. This is a repeat finding (2022-009) from the previous fiscal year. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Cambria Heights School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: Hranec Sheet Metal, Inc. - $1,058,759, Westmoreland Electric Services – $92,163. RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: In connection with the Cambria Heights School District’s RTU Replacement Project, the District did not perform debarment and suspension checks for contractors through SAM.gov. This is a repeat finding (2022-009) from the previous fiscal year. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Cambria Heights School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: Hranec Sheet Metal, Inc. - $1,058,759, Westmoreland Electric Services – $92,163. RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: In connection with the Cambria Heights School District’s RTU Replacement Project, the District did not perform debarment and suspension checks for contractors through SAM.gov. This is a repeat finding (2022-009) from the previous fiscal year. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Cambria Heights School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: Hranec Sheet Metal, Inc. - $1,058,759, Westmoreland Electric Services – $92,163. RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: In connection with the Cambria Heights School District’s RTU Replacement Project, the District did not perform debarment and suspension checks for contractors through SAM.gov. This is a repeat finding (2022-009) from the previous fiscal year. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. CAUSE: School District personnel were unaware that there was a website available to assist them in determining if a contractor/vendor was determined to be debarred or suspended from participating in federal assistance programs. EFFECT: The Cambria Heights School District did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: Hranec Sheet Metal, Inc. - $1,058,759, Westmoreland Electric Services – $92,163. RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
2023-006 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the City must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Service Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: During our testing of the City’s provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted for three (3) of four (4) contracts selecting for testing there was no evidence that the City verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. Cause: The City did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The City’s control was not consistently followed, which required verification of suspension or debarment prior to entering the contract. Subsequent to entering into the contract, management verified the vendors were not suspended or debarred. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of four (4) out of twelve (12) procurement contracts were sampled for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. Repeat Finding from Prior Year: No Recommendation: We recommend the City adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Finding 2023-048: U.S. Department of Health and Human Services ALN #93.423, 1332 State Innovation Waivers Grant #SIWIW200014 Criteria: Federal regulations, 2 CFR 200.214 and 2 CFR 180.300, require the State Auditor’s Office (office) to restrict subawards to parties not suspended or debarred from receiving federal funds. The 1332 State Innovation Waivers (waiver program) compliance supplement further requires the office to review the office to review the System for Award Management (SAM) website annually for its subrecipients. Federal regulation, 2 CFR 25.300, specifies subwards may not be made unless the subrecipient has obtained and provides its Unique Entity Identified (UEI) to the Federal grant recipient. Federal regulation, 2 CFR 170 Appendix A, states the Federal grant recipient must report each action that obligates federal funds to a subrecipient that equals or exceeds $30,000. Each obligating action must be reported to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) by the end of the month following the month in which the decision was made. Federal regulation, 2 CFR 200.303, requires non-Federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The office did not have adequate controls to identify all requirements related to its subaward under the waiver program, including the requirement to communicate specific information to its subrecipient, the Montana Reinsurance Association. Additionally, the office did not comply with suspension and debarment and reporting requirements applicable to the waiver program, as follows: • The office did not check the SAM excluded party list for suspensions and debarments and retain evidence of its review before issuing any subaward payments. Additionally, contrary to federal regulations, the office made subaward payments to the MRA prior to receiving its UEI. • The office did not submit reports for subaward information as required under FFATA. Questioned Costs: No questioned costs identified. Context: There is a single subrecipient for the waiver program. The office did not check the suspended or debarred status of the subrecipient during the audit period. Additionally, the office did not submit the required FFATA reports for $47.5 million in subwards made during fiscal years 2022 and 2023. We brought the internal control and compliance issues to the office’s attention in April 2023. As of June 14, 2023, the office updated its Annual Calendar used to track reporting and monitoring requirements. On this version of its Annual Calendar, the office scheduled an annual check of the SAM site for October 2023, but FFATA reporting was not yet incorporated into the calendar. On July 13, 2023, the office added FFATA reports to its Annual Calendar. Additionally, as of June 30, 2023, the office had neither checked the SAM excluded party listing nor obtained the MRA’s UEI. Between May and June 2023, the office incurred costs associated with the MRA totaling $283,334 in federal funds. Effect: The office has not complied with all elements of the Suspension and Debarment and Reporting compliance requirements. Internal control weaknesses also put the office at risk of additional noncompliance. Cause: While the office treated the MRA as its subrecipient in some respects, the office did not identify the need to treat the MRA as a subrecipient for all related requirements. The office relied on federal guidance provided when the state’s waiver was approved in 2019, which included the Specific Terms and Conditions. However, the office did not consider other requirements outlined in the federal Compliance Supplement for the waiver program, available as of August 2019 and at recurring intervals since that time, when determining procedures necessary to comply with all federal compliance requirements. Recommendation: We recommend the State Auditor’s Office: A. Enhance internal controls to monitor the excluded parties list, disclose all required information to its subrecipient, and complete required Federal Funding Accountability and Transparency Act reports. B. Comply with federal suspension and debarment requirements to review the SAM website prior to making subaward payments and to make subawards only to entities with a Unique Entity Identifier. C. Submit required Federal Funding Accountability and Transparency Act reports. Views of Responsible Officials: The office concurs with this recommendation. For more information on the office’s planned corrective action see the Corrective Action Plan starting on page D-1.
Finding 2023-048: U.S. Department of Health and Human Services ALN #93.423, 1332 State Innovation Waivers Grant #SIWIW200014 Criteria: Federal regulations, 2 CFR 200.214 and 2 CFR 180.300, require the State Auditor’s Office (office) to restrict subawards to parties not suspended or debarred from receiving federal funds. The 1332 State Innovation Waivers (waiver program) compliance supplement further requires the office to review the office to review the System for Award Management (SAM) website annually for its subrecipients. Federal regulation, 2 CFR 25.300, specifies subwards may not be made unless the subrecipient has obtained and provides its Unique Entity Identified (UEI) to the Federal grant recipient. Federal regulation, 2 CFR 170 Appendix A, states the Federal grant recipient must report each action that obligates federal funds to a subrecipient that equals or exceeds $30,000. Each obligating action must be reported to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) by the end of the month following the month in which the decision was made. Federal regulation, 2 CFR 200.303, requires non-Federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The office did not have adequate controls to identify all requirements related to its subaward under the waiver program, including the requirement to communicate specific information to its subrecipient, the Montana Reinsurance Association. Additionally, the office did not comply with suspension and debarment and reporting requirements applicable to the waiver program, as follows: • The office did not check the SAM excluded party list for suspensions and debarments and retain evidence of its review before issuing any subaward payments. Additionally, contrary to federal regulations, the office made subaward payments to the MRA prior to receiving its UEI. • The office did not submit reports for subaward information as required under FFATA. Questioned Costs: No questioned costs identified. Context: There is a single subrecipient for the waiver program. The office did not check the suspended or debarred status of the subrecipient during the audit period. Additionally, the office did not submit the required FFATA reports for $47.5 million in subwards made during fiscal years 2022 and 2023. We brought the internal control and compliance issues to the office’s attention in April 2023. As of June 14, 2023, the office updated its Annual Calendar used to track reporting and monitoring requirements. On this version of its Annual Calendar, the office scheduled an annual check of the SAM site for October 2023, but FFATA reporting was not yet incorporated into the calendar. On July 13, 2023, the office added FFATA reports to its Annual Calendar. Additionally, as of June 30, 2023, the office had neither checked the SAM excluded party listing nor obtained the MRA’s UEI. Between May and June 2023, the office incurred costs associated with the MRA totaling $283,334 in federal funds. Effect: The office has not complied with all elements of the Suspension and Debarment and Reporting compliance requirements. Internal control weaknesses also put the office at risk of additional noncompliance. Cause: While the office treated the MRA as its subrecipient in some respects, the office did not identify the need to treat the MRA as a subrecipient for all related requirements. The office relied on federal guidance provided when the state’s waiver was approved in 2019, which included the Specific Terms and Conditions. However, the office did not consider other requirements outlined in the federal Compliance Supplement for the waiver program, available as of August 2019 and at recurring intervals since that time, when determining procedures necessary to comply with all federal compliance requirements. Recommendation: We recommend the State Auditor’s Office: A. Enhance internal controls to monitor the excluded parties list, disclose all required information to its subrecipient, and complete required Federal Funding Accountability and Transparency Act reports. B. Comply with federal suspension and debarment requirements to review the SAM website prior to making subaward payments and to make subawards only to entities with a Unique Entity Identifier. C. Submit required Federal Funding Accountability and Transparency Act reports. Views of Responsible Officials: The office concurs with this recommendation. For more information on the office’s planned corrective action see the Corrective Action Plan starting on page D-1.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number: MA DESE Codes 240, 252, 262, 264 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the 1 vendor in our testing sample, the Town did not document verification that the vendor was not suspended or debarred from participation in Federal assistance programs or activities. The vendor in our audit sample was not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend the Town enhance procedures and controls to ensure verifications of suspension and debarment statuses are obtained and documented prior to executing transactions with vendors. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number: MA DESE Codes 240, 252, 262, 264 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the 1 vendor in our testing sample, the Town did not document verification that the vendor was not suspended or debarred from participation in Federal assistance programs or activities. The vendor in our audit sample was not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend the Town enhance procedures and controls to ensure verifications of suspension and debarment statuses are obtained and documented prior to executing transactions with vendors. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number: MA DESE Codes 240, 252, 262, 264 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the 1 vendor in our testing sample, the Town did not document verification that the vendor was not suspended or debarred from participation in Federal assistance programs or activities. The vendor in our audit sample was not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend the Town enhance procedures and controls to ensure verifications of suspension and debarment statuses are obtained and documented prior to executing transactions with vendors. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number: MA DESE Codes 240, 252, 262, 264 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For the 1 vendor in our testing sample, the Town did not document verification that the vendor was not suspended or debarred from participation in Federal assistance programs or activities. The vendor in our audit sample was not suspended or debarred. Questioned Costs: None. Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No. Recommendation: We recommend the Town enhance procedures and controls to ensure verifications of suspension and debarment statuses are obtained and documented prior to executing transactions with vendors. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Unknown Award Period: March 3, 2021 – December 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Town should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.214 requires compliance with suspension and debarment standards. Condition: No supporting documentation was maintained to support the vendor was not suspended or debarred. We confirmed that the vendors were not suspended or debarred. Questioned costs: None. Context: 2 of the 2 vendors tested. Cause: Procedures are not in place to maintain documentation verifying vendors are not suspended or debarred. Effect: Potential noncompliance with federal procurement, suspension, and debarment compliance requirements. Recommendation: We recommend the Town implement control to ensure adherence to the suspension and debarment requirements of the Uniform Guidance. Views of responsible officials: There is no disagreement with the audit finding.
LACK OF PROCEDURES TO ENSURE PROPER SUSPENSION AND DEBARMENT REQUIREMENTS Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant: SLFRP0923, March 3, 2021, through December 31, 2024 Federal Grantor: U.S. Department of the Treasury Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2023) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2023) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition: The County did not have controls in place to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay eleven vendors over $25,000 each, totaling $1,436,244, during the fiscal year ended June 30, 2023. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. Context: The County did not have a system in place to ensure proper application of the federal guidelines for the federal disbursements. Effect: Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Cause: Lack of procedures and knowledge regarding suspension and debarment requirements. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented.
Compliance - Per 2 CFR section 200.318, when procuring property, the non-Federal entity must have and use documented procurement procedures, consistent with States, for the acquisition of property or services required under a Federal award or subaward. Compliance - Per 2 CFR 200.214, restricts awards, subawards and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person (c) Adding a clause or condition to the covered transaction with that person. Control - Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The City was unable to provide documentation to support compliance with the required State procurement processes for acquiring property or services. In addition, the City did not provide support that the suspension and debarment status of the vendor was checked before the contract was awarded. Context For all contracts selected for testing, no support was provided for how the contract was procured. Further, the suspension and debarment status of the vendor was not documented for that contract. Questioned Costs Undetermined. Cause The City’s internal controls were not sufficient to ensure that applicable procurement policies and Federal suspension and debarment regulations were followed for purchased made for the program. Effect The City is not compliant with federal and state procurement and suspension and debarment requirements. Failure to adhere to procurement and suspension and debarment policies and procedures may result in obtaining goods and services under terms that are not in the best interest of the Federal program. Recommendation The City should review and enhance controls and procedures to ensure that it follows the applicable procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Views of responsible officials We agree with the auditor’s recommendation. The City of Harrington, Delaware will review the State’s procurement process to satisfy the compliance requirements for the program. The City of Harrington, Delaware will also put procedures in place to check and review each bidder as part of the Federal suspension and debarment policies.
Criteria Compliance - Per 2 CFR section 200.318, when procuring property, the non-Federal entity must have and use documented procurement procedures, consistent with States, for the acquisition of property or services required under a Federal award or subaward. Compliance - Per 2 CFR 200.214, restricts awards, subawards and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person (c) Adding a clause or condition to the covered transaction with that person. Control - Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The City was unable to provide documentation to support compliance with the required State procurement processes for acquiring property or services. In addition, the City did not provide support that the suspension and debarment status of the vendor was checked before the contract was awarded. Context For all contracts selected for testing, no support was provided for how the contract was procured. Further, the suspension and debarment status of the vendor was not documented for that contract. Questioned Costs Undetermined. Cause The City’s internal controls were not sufficient to ensure that applicable procurement policies and Federal suspension and debarment regulations were followed for purchased made for the program. Effect The City is not compliant with federal and state procurement and suspension and debarment requirements. Failure to adhere to procurement and suspension and debarment policies and procedures may result in obtaining goods and services under terms that are not in the best interest of the Federal program. Recommendation The City should review and enhance controls and procedures to ensure that it follows the applicable procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Views of responsible officials We agree with the auditor’s recommendation. The City of Harrington, Delaware will review the State’s procurement process to satisfy the compliance requirements for the program. The City of Harrington, Delaware will also put procedures in place to check and review each bidder as part of the Federal suspension and debarment policies
Criteria Compliance - Per 2 CFR section 200.318, when procuring property, the non-Federal entity must have and use documented procurement procedures, consistent with States, for the acquisition of property or services required under a Federal award or subaward. Compliance - Per 2 CFR 200.214, restricts awards, subawards and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person (c) Adding a clause or condition to the covered transaction with that person. Control - Per 2 CFR 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The City was unable to provide documentation to support compliance with the required State procurement processes for acquiring property or services. In addition, the City did not provide support that the suspension and debarment status of the vendor was checked before the contract was awarded. Context For all contracts selected for testing, no support was provided for how the contract was procured. Further, the suspension and debarment status of the vendor was not documented for that contract. Questioned Costs Undetermined. Cause The City’s internal controls were not sufficient to ensure that applicable procurement policies and Federal suspension and debarment regulations were followed for purchased made for the program. Effect The City is not compliant with federal and state procurement and suspension and debarment requirements. Failure to adhere to procurement and suspension and debarment policies and procedures may result in obtaining goods and services under terms that are not in the best interest of the Federal program. Recommendation The City should review and enhance controls and procedures to ensure that it follows the applicable procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Views of responsible officials We agree with the auditor’s recommendation. The City of Harrington, Delaware will review the State’s procurement process to satisfy the compliance requirements for the program. The City of Harrington, Delaware will also put procedures in place to check and review each bidder as part of the Federal suspension and debarment policies.
2023-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $453,359 Repeat Finding from Prior Year: Yes; Finding 2022-001 Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.
2023-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $453,359 Repeat Finding from Prior Year: Yes; Finding 2022-001 Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.
2023-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $453,359 Repeat Finding from Prior Year: Yes; Finding 2022-001 Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.
2023-001 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – ALN 10.553, 10.555 & 10.559 Significant Deficiency in Internal Controls Over Compliance and Compliance Finding Criteria: Per 2 CFR section 200.319, procurements must provide for full and open competition. Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: A competitive procurement process, which includes suspension and debarment certifications, was not properly performed by the Town for the purchase of school lunch food products. Cause: The Town utilized vendors that were previously contracted in prior years without performing a current procurement and suspension and debarment verification. Effect: The Town is not in compliance with Federal procurement or suspension and debarment requirements. Questioned Costs: $453,359 Repeat Finding from Prior Year: Yes; Finding 2022-001 Recommendation: The Town should implement procedures to perform competitive procurements, which include suspension and debarment certification, for all applicable purchases of goods and services. Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – CFDA 10.553 & 10.555 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for five covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-007. Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – CFDA 10.553 & 10.555 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for five covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-007. Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Child Nutrition Cluster – CFDA 10.553 & 10.555 Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for five covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The five vendors were ultimately verified as not being suspended or debarred from participating in federal awards. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-007. Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for two covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.
2023-009 U.S. Department of Agriculture Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X & 84.173X Significant Deficiency in Internal Controls Over Compliance Criteria: Per 2 CFR section 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Suspension and debarment compliance was not verified for two covered transactions. Cause: Lack of appropriate oversight resulted in required debarment checks not being performed or the appropriate certifications signed by the vendors. Effect: Grant transactions are not supported adequately, and the School is at risk of awarding contracts to vendors not eligible to participate in federal awards programs. The two vendors were ultimately verified as not being suspended or debarred from participating in federal awards. Questioned Costs: None Repeat Finding from Prior Year: No. Recommendation: The City should implement procedures to document that all contractors under covered transactions that are performing services for the grant are not suspended or debarred. Views of Responsible Official: Management agrees with the finding.