2022-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Department Of Agriculture Passed Through the South Dakota Department of Education Child Nutrition Cluster (CNC) Federal Financial Assistance Listing 10.553 School Breakfast Program (SBP) Federal Financial Assistance Listing 10.555 National School Lunch Program (NSLP) Federal Financial Assistance Listing 10.559 Summer Food Service Program For Children (SFSP) 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.214, sets forth the criteria for suspension and debarment requirements. Condition: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management agrees with the finding.
2022-003 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) Federal Financial Assistance Listing 84.425F Institutional Portion Award Number P425F202657, Award Years 2020 and 2021 Department Of Agriculture Passed Through the South Dakota Department of Education Child Nutrition Cluster (CNC) Federal Financial Assistance Listing 10.553 School Breakfast Program (SBP) Federal Financial Assistance Listing 10.555 National School Lunch Program (NSLP) Federal Financial Assistance Listing 10.559 Summer Food Service Program For Children (SFSP) 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance and Non-Compliance Criteria: 2 CFR section 200.214, sets forth the criteria for suspension and debarment requirements. Condition: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the School District had verified that the vendors were not suspended or debarred prior to purchases. Cause: Vendors are not being checked for suspension and debarment consistently prior to covered transactions when large purchases are made through the School District?s voucher process rather than the purchase order process. Effect: These errors could result in payment to suspended or debarred vendors. Questioned Costs: None. Context/Sampling: For HEERF, one of the 3 tested vendors did not have documented suspension and debarment verification with a total population of 4 vendors. For the Child Nutrition Cluster testing, one of the 7 tested vendors did not have documented suspension and debarment verification with a total population of 55 vendors. Repeat Finding from Prior Year(s): Yes, Finding 2021-005. Recommendation: We recommend that all purchases with amounts expected to go over $25,000 be vetted through the School District?s purchase order process to ensure proper procurement, suspension, and debarment policies are adequately followed for covered transactions. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Massachusetts Department of Elementary & Secondary Education Pass-Through Number(s): 09-344 Award Period: July 1, 2021 ? June 30, 2022 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 one vendor in our statistically valid sample, the Town received a certification of suspension and debarment status dated November 1, 2021. The previous certification received from the vendor was dated January 21, 2020. Certifications (or other methods of verification) should be received/performed every 12 months at a minimum. Questioned Costs: None. Cause: Procedures were not in place to timely 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 instance 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 procedures be implemented to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Massachusetts Department of Elementary & Secondary Education Pass-Through Number(s): 09-344 Award Period: July 1, 2021 ? June 30, 2022 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 one vendor in our statistically valid sample, the Town received a certification of suspension and debarment status dated November 1, 2021. The previous certification received from the vendor was dated January 21, 2020. Certifications (or other methods of verification) should be received/performed every 12 months at a minimum. Questioned Costs: None. Cause: Procedures were not in place to timely 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 instance 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 procedures be implemented to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Pass-Through Agency: Massachusetts Department of Elementary & Secondary Education Pass-Through Number(s): 09-344 Award Period: July 1, 2021 ? June 30, 2022 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 one vendor in our statistically valid sample, the Town received a certification of suspension and debarment status dated November 1, 2021. The previous certification received from the vendor was dated January 21, 2020. Certifications (or other methods of verification) should be received/performed every 12 months at a minimum. Questioned Costs: None. Cause: Procedures were not in place to timely 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 instance 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 procedures be implemented to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-004 Information on the federal program: Subject: Child Nutrition Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: National School Lunch Program Assistance Listing Number: 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 20-21, FY 21-22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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)...." 2 CFR 200.214 States in part: "Non-federal entities and contractors are subject to the non-procurement 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." 2CFR 200.318 (a) states in part: "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." (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "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 following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-004 (Continued) (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Indiana Code 5-22-8-3 states in part: "(a) . . . if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) . . . the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. There was no documented control over procurements made under the small purchase threshold. Cause: Management had not developed a system of internal control that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not provide audit evidence that it verified that vendors which were paid $25,000 or more per school year were not excluded or disqualified from participation in federal award programs. Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-004 (Continued) Identification as a repeat finding: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-004 Information on the federal program: Subject: Child Nutrition Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: National School Lunch Program Assistance Listing Number: 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 20-21, FY 21-22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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)...." 2 CFR 200.214 States in part: "Non-federal entities and contractors are subject to the non-procurement 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." 2CFR 200.318 (a) states in part: "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." (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "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 following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-004 (Continued) (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in ? 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases? (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Indiana Code 5-22-8-3 states in part: "(a) . . . if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) . . . the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. There was no documented control over procurements made under the small purchase threshold. Cause: Management had not developed a system of internal control that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not provide audit evidence that it verified that vendors which were paid $25,000 or more per school year were not excluded or disqualified from participation in federal award programs. Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-004 (Continued) Identification as a repeat finding: No. Recommendation: We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 Services 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 (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA 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. See separate corrective action plan.
2022-003 - Written Policies Required by the Uniform Grant Guidance Finding Type: Material Weakness over Federal Awards Programs: Capitalization Grants for Clean Water Revolving Funds (Assistance Listing Number 66.458) Criteria: Per 2 CFR ? 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. Condition/Finding: The City had no controls in place, as required by the Uniform Guidance, to ensure that all parties that the City enters into covered transactions with are eligible for participation in federal assistance programs or activities. However, during our testing, we found that all covered transactions entered into by the City were with eligible parties. Cause: The City did not have written policies and procedures over procurement, including suspension and debarment, as required by the Uniform Guidance. Effect: As a result of this condition, the City had increased risk of inadvertently entering into a covered transaction with an ineligible party. Questioned Costs: No costs have been questioned as a result of this finding. Repeat Finding: No Recommendation: We recommend that the City Commission and management adopt, and follow, written policies and procedures (that conform with requirements of the Uniform Guidance) to ensure that future contracts are properly documented and awarded in a manner that documents that the City verified all parties under covered transactions are eligible for participation in federal programs or activities. View of Responsible Officials (Corrective Action): See corrective action plan.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 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: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 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: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 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: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 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: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 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: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
Finding 2022-003 ? Procurement. (ALN 84.010 Title I grants to local educational agencies; ALN 84.425D ESSER I, ALN 84.425D ESSER II, ALN 84.425U ARP ESSER; ALN 84.367 Supporting effective instruction ? state grants; and ALN 84.424 Student support and academic enrichment programs) CRITERIA: 2 CFR 200.318 (i) states that a non-federal entity must maintain records sufficient to detail the history of procurement. 2 CFR 200.320(b) states that when the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold ($250,000 for the 2021-2022 year), formal procurement methods are required and may include sealed bids and/or proposals. Formal procurement methods require documenting procedures. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. The non-federal entity must have a written method for conducting technical evaluations of the proposals received and making selections. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 2 CFR 200.319 or paragraph ? of 2 CFR 200.320. 2 CFR 200.321 states that the non-federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations outlined in 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: During our testing of nonpayroll expenditures, we noted 24 purchase orders issued under a formal request for proposal (RFP) process used to secure instructional consulting services for a three year period to include the 2021-2022 school year. There was no evidence to show that public advertising was used to solicit vendors. Instead, vendors were solicited through email communications. There was no evidence that the district took all necessary steps to assure that minority businesses and women?s business enterprises were used when possible. There was no evidence to support detailed vendor selection or rejection methods. The evaluation process was informal and not documented. There was no evidence to support that vendor suspension or debarment statuses were checked at the time of the informal evaluation of the RFP or at the time purchase orders were issued. Daily consulting rates submitted by the various vendors responding to the RFP were identical rates or nearly identical rates. We noted instructional consulting expenditures awarded under the RPF during the 2021-2022 year in excess of the simplified acquisition threshold as follows: ALN 84.010 Title I grants to local educational agencies - $396,876.76 ALN 84.425 Elementary and secondary school emergency relief fund (ESSER) - $266,686.62 We noted instructional consulting expenditures awarded under the RFP during the 2021-2022 year that were under the simplified acquisition threshold as follows: ALN 84.367 Supporting effective instruction ? state grants - $102,171.59 ALN 84.424 Student support and academic enrichment program - $7,654.72 CAUSE: Likely there was confusion about the RFP process and the requirements inherent in that process. EFFECT: While competition was introduced into the proposal process for procurement of instructional consulting services for the 2021-2022 school year, the process used by the district was highly informal and did not include all of the requirements of 2 CFR 200 with respect to federal procurement standards. QUESTIONED COSTS: None. RECOMMENDATION: We recommend that the district follow all of the requirements of 2 CFR 200 with respect to federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS: See the school district?s response in the auditee?s corrective action plan in this report.
SECTION III - FEDERAL AND STATE AWARD FINDINGS AND QUESTIONED COSTS 2022-002 SUSPENSION AND DEBARMENT Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund (ESF) ALN Numbers: 84.425 ? COVID-19: Higher Education Emergency Relief Fund ? Student Aid 84.425 ? COVID-19: Higher Education Emergency Relief Fund ? Institutional Portion Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - 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. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to nonprocurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that one vendor were not suspended or debarred prior to the purchase. Questioned costs: None Context: For 1 of the 6 vendors selected for testing in a non-statistically valid sample, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their control processes related to the verification and documentation of the vendor?s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation of the internal control process over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.
SECTION III - FEDERAL AND STATE AWARD FINDINGS AND QUESTIONED COSTS 2022-002 SUSPENSION AND DEBARMENT Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund (ESF) ALN Numbers: 84.425 ? COVID-19: Higher Education Emergency Relief Fund ? Student Aid 84.425 ? COVID-19: Higher Education Emergency Relief Fund ? Institutional Portion Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR Part 200 Section 200.214 - 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. Grant recipients are required to design and implement control process to ensure grant requirements are complied with, including requires related to nonprocurement debarment and suspension regulations. Condition: During our testing, we noted the District was not able to provide documentation of compliance with their control process and evidence that one vendor were not suspended or debarred prior to the purchase. Questioned costs: None Context: For 1 of the 6 vendors selected for testing in a non-statistically valid sample, the District did not retain documentation that they had verified that the vendor was not suspended or debarred by the Federal Government prior to purchase. The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of compliance with their internal controls over these compliance requirements provides an opportunity for noncompliance. Cause: The District did not retain documentation of their control processes related to the verification and documentation of the vendor?s status as not suspended or debarred with the Federal Government. Effect: The lack of documentation of the internal control process over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury Federal Financial Assistance Listing: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance, Instance of Non-compliance Criteria: General procurement standards 2 CFR 200.318 require the non-Federal entity to use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and standards identified in this part. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in 2 CFR sections 200.317 through 200.326. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 2 CFR section 200.214. Condition: The following required procurement standards were not addressed in the City's policy: ? Conflict of interest, including disciplinary actions for failure to adhere (2 CFR 200.318) ? Avoid acquisition of duplicative items (2 CFR 200.318) ? Cost effective purchasing (2 CFR 200.318) ? Document retention (2 CFR 200.318) ? Provisions to ensure all solicitations (2 CFR 200.319): Incorporate clear and accurate descriptions of technical requirements, do not restrict competition, and identify all requirements which the offerors must fulfill and factors used in evaluation ? Disadvantaged Business Enterprise program (2 CFR 200.321) ? Recovered materials, if subject to EPA requirements (2 CFR 200.322) ? Contract price/types (2 CFR 200.323) ? Bonding requirements (2 CFR 200.325) ? Contract provisions (2 CFR 200.326) Additionally, we identified 3 instances in which the City did not verify the vendor was not suspended, debarred, or otherwise excluded before entering into a covered transaction rather, verification was performed after entering into the transaction. The City asserted that they verified the vendors were not suspended or debarred; however, no documentation of the procedure being performed prior to entering into the transaction was presented. Cause: The City?s did not ensure it?s written procedures identified all of the required federal procurement standards. Additionally, the City?s controls did not ensure the check for suspension and debarment was performed and documented prior to entering into covered transactions. Effect: The City?s documented procurement procedures do not conform to the procurement standards identified in 2 CFR sections 200. 318, 200.319, and 200.321 through 200.326. Additionally, the City did not comply with the requirements of 2 CFR 200.214. Questioned Costs: None reported. Context/Sampling: The condition noted above was identified during our procedures related to procurement, suspension, and debarment. A non-statistical sample of 4 expenditures out of a population of 12 vendors were selected for testing as a whole. Repeat Finding from Prior Year: No. Recommendation: We recommend the City modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Reference Number: 2022-003 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Department Name: Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: 1DE303301 (10/1/2020 ? 9/30/2022) Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR 200.214 Suspension and Debarment 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; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 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 Department of Education (Department) did not determine the suspension and debarment status of subrecipients with expenditures exceeding $25,000 as required by federal regulations. Context: The suspension and debarment status for 1 of 5 subrecipients was not documented. Questioned costs: There are no questioned costs related to this finding as the subrecipient was not federally suspended or debarred. Cause: The Department?s procedures and internal controls over suspension and debarment are not sufficient to ensure that all subrecipients? suspension and debarment status is verified timely. Effect: Failure to verify the suspension and debarment status of subrecipients may result in the State issuing subawards to subrecipients that are suspended or debarred and not authorized to provide services under the program. Recommendation: The Department should ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all subrecipients prior to issuance of the subawards. Views of responsible officials: The Delaware Department of Education (DDOE) Nutrition Team will update the online School Nutrition application to include a certification statement similar to the statement below. Have any current principal staff been debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from participation in this transaction by any Federal department or agency. Yes/No. The DDOE Nutrition Team will check SAM exclusions on sam.gov until the application is updated.
Reference Number: 2022-003 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Department Name: Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: 1DE303301 (10/1/2020 ? 9/30/2022) Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR 200.214 Suspension and Debarment 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; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 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 Department of Education (Department) did not determine the suspension and debarment status of subrecipients with expenditures exceeding $25,000 as required by federal regulations. Context: The suspension and debarment status for 1 of 5 subrecipients was not documented. Questioned costs: There are no questioned costs related to this finding as the subrecipient was not federally suspended or debarred. Cause: The Department?s procedures and internal controls over suspension and debarment are not sufficient to ensure that all subrecipients? suspension and debarment status is verified timely. Effect: Failure to verify the suspension and debarment status of subrecipients may result in the State issuing subawards to subrecipients that are suspended or debarred and not authorized to provide services under the program. Recommendation: The Department should ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all subrecipients prior to issuance of the subawards. Views of responsible officials: The Delaware Department of Education (DDOE) Nutrition Team will update the online School Nutrition application to include a certification statement similar to the statement below. Have any current principal staff been debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from participation in this transaction by any Federal department or agency. Yes/No. The DDOE Nutrition Team will check SAM exclusions on sam.gov until the application is updated.