CONDITION: Per the on-site monitoring report of the City’s Community Development Block Grant (CDBG) Program performed by the Department of Housing and Urban Development dated May 15, 2024, the City purchased a device called ShotSpotter with CDBG contract B-20-MC-42-0106 funding in the amount of $99,000. The City of McKeesport did not verify if the above vendor was on the excluded parties list in the System for Award Management through www.sam.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. In addition, the City’s Community Development Block Grant Policies & Procedures Manual in Section VIII for procurement requires this step to be performed. CAUSE: It was not readily determinable as to why this procedural step was overlooked by applicable City personnel during the procurement process. EFFECT: The City of McKeesport did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance, nor Section VIII of the City’s CDBG Policies & Procedures Manual for procurement, regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: $99,000 RECOMMENDATION: I am recommending that the management of the City utilize the www.sam.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance, and Section VIII of the City’s CDBG Policies & Procedures Manual for procurement. VIEWS OF RESPONSIBLE OFFICIALS: The City concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: Per the on-site monitoring report of the City’s Community Development Block Grant (CDBG) Program performed by the Department of Housing and Urban Development dated May 15, 2024, the City purchased a device called ShotSpotter with CDBG contract B-20-MC-42-0106 funding in the amount of $99,000. The City of McKeesport did not verify if the above vendor was on the excluded parties list in the System for Award Management through www.sam.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. In addition, the City’s Community Development Block Grant Policies & Procedures Manual in Section VIII for procurement requires this step to be performed. CAUSE: It was not readily determinable as to why this procedural step was overlooked by applicable City personnel during the procurement process. EFFECT: The City of McKeesport did not comply with the requirements of Section 2 CFR 200.214 of the Uniform Guidance, nor Section VIII of the City’s CDBG Policies & Procedures Manual for procurement, regarding the procedure required to determine whether a contractor/vendor was debarred or suspended from participating in federal assistance programs. QUESTIONED COST: $99,000 RECOMMENDATION: I am recommending that the management of the City utilize the www.sam.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance, and Section VIII of the City’s CDBG Policies & Procedures Manual for procurement. VIEWS OF RESPONSIBLE OFFICIALS: The City concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
2021-006 Suspension and DebarmentProgram Information Federal Agency U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers 21H8FCS41567C6, H8C35204, H8D36710, H7CHA37307 Criteria [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transaction (procurement contracts, purchase orders, or agreements greater than or equal to $25,000) with persons or vendors. Condition The Organization did not retain appropriate evidence of verification that vendors and contractors were not excluded from doing business with the federal government. Context This finding appears to be a systemic problem. Out of four covered vendors selected, none had evidence that an exclusion check was performed prior to related expenditures. Cause The Organization did not retain for its records proof that the verification check of vendors and contractors was made, and did not have policies and procedures in place to ensure this was done. Effect The Organization may have entered into covered transactions with persons or vendors who have been suspended or debarred. Questioned Costs None noted. Recommendation We recommend the Organization implement controls requiring that exclusion checks be performed prior to signing any contracts or purchase orders or agreements that are covered transactions. This exclusion checks should be maintained as part of the supporting documentation for the expenditure. View of responsible officials and planned corrective action The Organization acknowledges the material weakness related to the lack of documented verification of vendor suspension and debarment status. While the organization is confident vendors were appropriate screened through SAM.gov - we acknowledge proper supporting documentation was not maintained. Corrective Actions • Policy and Procedure Implementation: The Organization has implemented formal procurement procedures requiring suspension and debarment (SAM) checks prior to entering into any covered transactions exceeding $25,000. • Documentation Requirements: Evidence of exclusion checks is now required to be retained and maintained with the supporting procurement and expenditure documentation. • Process Integration and Oversight: Exclusion verification has been incorporated into the procurement and approval workflow to ensure compliance is performed consistently before contract execution or payment. In alignment with broader control enhancements noted previously, these actions establish a consistent and documented process to ensure compliance with federal requirements and prevent engagement with excluded or disqualified parties going forward.