FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
U.S. Department of Health and Human Services - 93.432 Center for Independent Living 2024-006 Lack of Documentation for Suspension and Debarment Verification Criteria: Per 2 CFR §180.300 and 2 CFR §200.214, entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify a vendor's status using SAM.gov and maintain documentation as evidence of compliance with this requirement. Condition: During our audit procedures related to procurement under federal awards, we noted that the League did not maintain documentation showing that vendors and contractors paid with federal funds were checked against the System for Award Management (SAM.gov) to verify they were not suspended or debarred. While management stated that vendors are routinely reviewed on SAM.gov prior to engagement, there was no evidence, such as printouts, screenshots, or other records, retained to support that the checks had occurred. Cause: The League did not have a formal process in place to document and retain evidence of suspension and debarment checks. Verification procedures were informal and not consistently recorded. Effect: Without documented evidence of suspension and debarment checks, the League cannot demonstrate compliance with federal procurement requirements. This increases the risk that federal funds could be paid to ineligible vendors, which may result in questioned costs or noncompliance findings. Questioned Costs: None noted. Recommendation: We recommend the League establish and implement a formal policy requiring documentation of all SAM.gov suspension and debarment checks for vendors paid with federal funds. This may include saving screenshots or printouts of the SAM.gov search results, retaining vendor verification logs, or using automated tools if available. Documentation should be maintained in accordance with federal record retention requirements. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan on page 50.
Finding 2024-004 – PROCUREMENT (repeat finding) Type: Material Weakness in Internal Control/Noncompliance. Program: ALN 93.493 Congressional Directives Grant Name: Access to Behavioral Crisis Services Grantor Number: FG-22-099 Criteria: Pursuant to 2 CFR 200.320, when a procurement transaction under a Federal award exceeds the simplified acquisition threshold, formal procurement methods are required. Pursuant to 2 CFR 200.214 and 2 CFR part 180, prior to entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified.” Condition: The CMHSP did not follow the formal procurement methods outlined in 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant. Cause: This condition was caused by an insufficient internal control process for procurement including 1) requirement/review and approval of formal bid, and 2) review for suspension and debarment. Effect: The CMHSP purchased several items pursuant to a contract that did not go through a formal bid process or have evidence of review for suspension and debarment. Questioned Cost: $340,014 Context: One contract was paid from grant funds. The questioned cost shown above reflects the amount paid from grant funds for the year pursuant to this contract which did not go through a formal bid process or have evidence of review for suspension and debarment. Upon subsequent review, it was determined that the vendor was not suspended, debarred, or otherwise excluded or disqualified. Recommendation: We recommend that the CMHSP review their internal controls and make necessary changes to ensure that procurements adhere to the requirements of 2 CFR 200. Management’s Resp: We are in agreement with this finding.
Condition: The Organization did not maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance, for procurement transactions under a federal award or subaward. The Organization also did not comply with 2 CFR 200.318 (h) and 200.214 of the Uniform Guidance including verifying that vendors for covered transactions are not debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. There were two vendors with covered transactions charged to the major program. The vendors were not debarred, suspended, or otherwise excluded. However, the Organization did not perform and document the required verification. Criteria: The Uniform Guidance requires the Organization to maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327, for procurement transactions under a federal award or subaward. The Uniform Guidance 2 CFR 200.318 (h) and 200.214 also require the Organization to verify that vendors for covered transactions are not debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Cause: The relevant procedures were not documented in a manner required by the Uniform Guidance. There was a weakness in controls involving compliance with procurement, suspension, and debarment requirements. Effect: The Organization was not in compliance with the Uniform Guidance. Recommendation: The Organization should draft and maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. See the Corrective Action Plan.
Procurement, and Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN: 84.126 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: H126A220092, H126A230092, H126A240092 October 1, 2021– September 30, 2023, October 1, 2022 – September 30, 2024, and October 1, 2023 – September 30, 2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce Commission (TWC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.214, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Per 2 CFR 180.505 – Who uses SAM.gov Exclusions? (a) Federal agency officials use SAM.gov Exclusions to determine whether to enter into a transaction with a person, as required under § 180.430. (b) Participants also may, but are not required to, use SAM.gov Exclusions to determine if: (1) Principals of their transactions are excluded or disqualified, as required under § 180.320; or (2) Persons with whom they are entering into covered transactions at the next lower tier are excluded or disqualified. (c) The SAM.gov Exclusions are available to the general public. Condition: TWC’s Procurement and Contract Management Handbook (Revised April 2024) states that vendor compliance verifications include checking the Comptroller’s vendor performance tracking system, debarment, federal database checks and other verifications. A vendor that fails a verification may not move forward in the evaluation process and receive a contract award. Audit procedures included testing 34 procurements during the fiscal year to test whether vendor compliance verifications were completed prior to entering into a covered transaction. During our testing, we noted the following instances of noncompliance: For one procurement, the vendor compliance verification was completed for the incorrect vendor. A search was completed for the director of the organization rather than the legal entity name. For four of the procurements, a valid date stamp was not available to confirm the verification was completed prior to entering into a covered transaction. Questioned costs: None Context: See “Condition.” Cause: Individuals performing the vendor compliance checks were not adequately trained on the requirements and timeline that must be adhered to per TWC’s Procurement and Contract Management Handbook and federal guidelines. Effect: Failure to complete proper vendor compliance checks prior to entering into a covered transaction may lead to entering into contracts with suspended or disbarred vendors that could result in noncompliance and questioned costs. Repeat Finding: No Recommendation: We recommend that TWC provide additional training to individuals performing vendor compliance checks. We also recommend TWC establish internal controls to monitor that vendor compliance checks are being completed accurately and timely. Views of responsible officials: TWC’s Procurement and Contract Management (PCS) agrees with the recommendations.
Procurement, and Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN: 84.126 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: H126A220092, H126A230092, H126A240092 October 1, 2021– September 30, 2023, October 1, 2022 – September 30, 2024, and October 1, 2023 – September 30, 2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce Commission (TWC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.214, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Per 2 CFR 180.505 – Who uses SAM.gov Exclusions? (a) Federal agency officials use SAM.gov Exclusions to determine whether to enter into a transaction with a person, as required under § 180.430. (b) Participants also may, but are not required to, use SAM.gov Exclusions to determine if: (1) Principals of their transactions are excluded or disqualified, as required under § 180.320; or (2) Persons with whom they are entering into covered transactions at the next lower tier are excluded or disqualified. (c) The SAM.gov Exclusions are available to the general public. Condition: TWC’s Procurement and Contract Management Handbook (Revised April 2024) states that vendor compliance verifications include checking the Comptroller’s vendor performance tracking system, debarment, federal database checks and other verifications. A vendor that fails a verification may not move forward in the evaluation process and receive a contract award. Audit procedures included testing 34 procurements during the fiscal year to test whether vendor compliance verifications were completed prior to entering into a covered transaction. During our testing, we noted the following instances of noncompliance: For one procurement, the vendor compliance verification was completed for the incorrect vendor. A search was completed for the director of the organization rather than the legal entity name. For four of the procurements, a valid date stamp was not available to confirm the verification was completed prior to entering into a covered transaction. Questioned costs: None Context: See “Condition.” Cause: Individuals performing the vendor compliance checks were not adequately trained on the requirements and timeline that must be adhered to per TWC’s Procurement and Contract Management Handbook and federal guidelines. Effect: Failure to complete proper vendor compliance checks prior to entering into a covered transaction may lead to entering into contracts with suspended or disbarred vendors that could result in noncompliance and questioned costs. Repeat Finding: No Recommendation: We recommend that TWC provide additional training to individuals performing vendor compliance checks. We also recommend TWC establish internal controls to monitor that vendor compliance checks are being completed accurately and timely. Views of responsible officials: TWC’s Procurement and Contract Management (PCS) agrees with the recommendations.
U.S. Department of Housing and Urban Development #14.251 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants 2024-006 Lack of Documentation for Suspension and Debarment Verification Criteria: Per 2 CFR §180.300 and 2 CFR §200.214, entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify a vendor's status using SAM.gov and maintain documentation as evidence of compliance with this requirement. Condition: While the Organization has a written procurement policy that references compliance with federal procurement standards, there was no documentation to demonstrate that suspension and debarment verifications were performed for vendors or contractors paid with federal funds during the year. Cause: Although the Organization has a procurement policy in place, the procedures for documenting suspension and debarment verification were not consistently followed or retained. Effect: Without documentation of suspension and debarment checks, there is an increased risk that federal funds could be expended with a vendor or contractor that is ineligible to receive federal awards, resulting in potential noncompliance with federal regulations. Questioned Costs: None noted. Recommendation: We recommend the Organization strengthen implementation of its procurement policy by requiring documentation of suspension and debarment checks be included in all procurement files for federal funded contracts. This may include saving screenshots or printouts of the SAM.gov search results, retaining vendor verification logs, or using automated tools if available. Documentation should be maintained in accordance with federal record retention requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees documentation must be retained. Corrective Action: Management has implemented a formal process to document vendor eligibility verficiation. As of FY 2025, all vendors are revewied in SAM. gov prior to payment or contract execution, and a screenshot or PDF of the verification is saved to the Vendor Verification Log. The Grants & Finance Manager maintains this documentation as part of the procurement file.
Program - AL 21.027 - COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year - SLFRP1468; March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2024) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that vendors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition - The County could not provide documentation to support that the County implementedeffective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay two vendors over $25,000, totaling $548,036 during the fiscal year ended June 30, 2024. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed sam.gov and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - The following table provides details of the covered transactions noted: Cause - Lack of procedures and knowledge regarding suspension and debarment requirements. Effect - Without adequate procedures to ensure vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into acovered transaction, that a vendor is not suspended, debarred, or otherwise excluded fromor ineligible for participation in Federal programs or activities, and those procedures areadequately documented. View of Officials - The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented.
Finding # 2024-002 Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year: SLFRP0847, March 3, 2021, through December 31, 2024 Federal Grantor Agency: U.S. Department of the Treasury Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.214 (January 1, 2024) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. Condition: Dawson County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay 12 vendors over $25,000 each, totaling $2,875,367, during the fiscal year ended June 30, 2024. The County was unable to support that a review was performed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov, and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding: 2023-002 Questioned Costs: None Statistical Sample: No Context: The following table provides details of the covered transactions noted: Cause: Lack of procedures and knowledge regarding suspension and debarment requirements; long-time County Clerk retired during the fiscal year. Effect: Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials: The County has procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred.
Programs Affected 21.027 COVID-19 State and Local Fiscal Recovery Funds Criteria 2 CFR 200.318 requires that non-federal entities must maintain written standards establishing its procurement policies. Additionally, CFR 200.214 requires that non-federal entities establish internal controls to restrict transactions with parties that are debarred, suspended, or otherwise excluded from participation in federal assistance programs or activities. Condition and Context Through our compliance testing, it was noted that the Organization did not compare recipients of federal funds to the exclusion database of the Office of Inspector General for disbursements during the year ended June 30, 2024. Additionally, the Organization did not establish written policies regarding procurements and conflicts of interest. Cause and Effect The conditions identified were a result of the Organization not establishing policies and procedures to help ensure compliance with Uniform Guidance. The non statistical sample of 20 recipients of federal funds did not identify any recipients of federal funds who were excluded parties. Questioned Costs N/A Identification of Repeat Findings N/A Recommendation We recommend the Organization perform a comparison of all recipients of federal funds to the Office of Inspector General's database to ensure all are permitted to receive grant funding prior to issuance of payment. The search results should be documented. We also recommend the Organization establish a written procurement policy and conflict of interest policy. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.
Programs Affected 21.027 COVID-19 State and Local Fiscal Recovery Funds Criteria 2 CFR 200.318 requires that non-federal entities must maintain written standards establishing its procurement policies. Additionally, CFR 200.214 requires that non-federal entities establish internal controls to restrict transactions with parties that are debarred, suspended, or otherwise excluded from participation in federal assistance programs or activities. Condition and Context Through our compliance testing, it was noted that the Organization did not compare recipients of federal funds to the exclusion database of the Office of Inspector General for disbursements during the year ended June 30, 2024. Additionally, the Organization did not establish written policies regarding procurements and conflicts of interest. Cause and Effect The conditions identified were a result of the Organization not establishing policies and procedures to help ensure compliance with Uniform Guidance. The non statistical sample of 20 recipients of federal funds did not identify any recipients of federal funds who were excluded parties. Questioned Costs N/A Identification of Repeat Findings N/A Recommendation We recommend the Organization perform a comparison of all recipients of federal funds to the Office of Inspector General's database to ensure all are permitted to receive grant funding prior to issuance of payment. The search results should be documented. We also recommend the Organization establish a written procurement policy and conflict of interest policy. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.
2024-001 – Suspension and Debarment Finding Type: Significant deficiency in internal control over compliance Program: ALN 20.933 – National Infrastructure Investments ALN 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Criteria: As required by 2 CFR 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 receiving or participating in Federal awards. Condition: The vendors used for these grants were not checked for suspension and debarment prior to execution of the contract. Cause/Effect: Although a policy has been adopted requiring a check the suspension and debarment status prior to entering into contracts, the internal control over this process was not operating as designed. Questioned Cost: None. Recommendation: We recommend that the City update procedures to ensure that a check of suspension and debarment status is obtained prior to entering into a covered transaction. View of Responsible Official: Management is in agreement with this recommendation.
2024-001 – Suspension and Debarment Finding Type: Significant deficiency in internal control over compliance Program: ALN 20.933 – National Infrastructure Investments ALN 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Criteria: As required by 2 CFR 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 receiving or participating in Federal awards. Condition: The vendors used for these grants were not checked for suspension and debarment prior to execution of the contract. Cause/Effect: Although a policy has been adopted requiring a check the suspension and debarment status prior to entering into contracts, the internal control over this process was not operating as designed. Questioned Cost: None. Recommendation: We recommend that the City update procedures to ensure that a check of suspension and debarment status is obtained prior to entering into a covered transaction. View of Responsible Official: Management is in agreement with this recommendation.
Assistance Listing Number, Federal Agency, and Program Name - 97.044, U.S. Department of Homeland Security, Assistance to Firefighters Grant Federal Award Identification Number and Year - Not available Pass through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The City used the grant to procure goods and services from 13 different contractors and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Cause and Effect - The City did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs. Recommendation - We recommend the City strengthen its controls to ensure documentation is maintained to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - This item relates to turnover and transition within the purchasing division of the City during the last two years for all of the staff finalizing procurement matters that were replaced due to resignations and retirements. Upon notification of the deficiency, a root cause investigation on the actions involved during the grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the finance department, which includes purchasing division, operating departmental procurement requestors using federal grant awards, and all accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements.
Assistance Listing Number, Federal Agency, and Program Name - 97.044, U.S. Department of Homeland Security, Assistance to Firefighters Grant Federal Award Identification Number and Year - Not available Pass through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The City used the grant to procure goods and services from 13 different contractors and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Cause and Effect - The City did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs. Recommendation - We recommend the City strengthen its controls to ensure documentation is maintained to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - This item relates to turnover and transition within the purchasing division of the City during the last two years for all of the staff finalizing procurement matters that were replaced due to resignations and retirements. Upon notification of the deficiency, a root cause investigation on the actions involved during the grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the finance department, which includes purchasing division, operating departmental procurement requestors using federal grant awards, and all accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements.
Assistance Listing Number, Federal Agency, and Program Name - 97.044, U.S. Department of Homeland Security, Assistance to Firefighters Grant Federal Award Identification Number and Year - Not available Pass through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The City used the grant to procure goods and services from 13 different contractors and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Cause and Effect - The City did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs. Recommendation - We recommend the City strengthen its controls to ensure documentation is maintained to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - This item relates to turnover and transition within the purchasing division of the City during the last two years for all of the staff finalizing procurement matters that were replaced due to resignations and retirements. Upon notification of the deficiency, a root cause investigation on the actions involved during the grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the finance department, which includes purchasing division, operating departmental procurement requestors using federal grant awards, and all accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements.
Assistance Listing Number, Federal Agency, and Program Name - 97.044, U.S. Department of Homeland Security, Assistance to Firefighters Grant Federal Award Identification Number and Year - Not available Pass through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The City used the grant to procure goods and services from 13 different contractors and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Cause and Effect - The City did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs. Recommendation - We recommend the City strengthen its controls to ensure documentation is maintained to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - This item relates to turnover and transition within the purchasing division of the City during the last two years for all of the staff finalizing procurement matters that were replaced due to resignations and retirements. Upon notification of the deficiency, a root cause investigation on the actions involved during the grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the finance department, which includes purchasing division, operating departmental procurement requestors using federal grant awards, and all accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements.
Assistance Listing Number, Federal Agency, and Program Name - 97.044, U.S. Department of Homeland Security, Assistance to Firefighters Grant Federal Award Identification Number and Year - Not available Pass through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The City could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The City used the grant to procure goods and services from 13 different contractors and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Cause and Effect - The City did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs. Recommendation - We recommend the City strengthen its controls to ensure documentation is maintained to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - This item relates to turnover and transition within the purchasing division of the City during the last two years for all of the staff finalizing procurement matters that were replaced due to resignations and retirements. Upon notification of the deficiency, a root cause investigation on the actions involved during the grant procurement were performed to identify cause. The outcome of this investigation will be communicated as educational training within the finance department, which includes purchasing division, operating departmental procurement requestors using federal grant awards, and all accountants. Additionally, management has amended the standard policy for the City to ensure all federal monies are used in accordance with 2 CFR requirements.
Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the District 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 2024 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 pass-through 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: As a result of our testwork, we noted three (3) out of three (3) instances where there was no evidence that the District verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. However, none of the payments in our sample were made to a suspended or debarred party. Cause: The District did not have policies and procedures in place to verify the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. Effect: The District lacked documentation to support compliance with suspension and debarment requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Suspension and debarment was applicable to 3 subrecipients. We tested all 3 subrecipients during the year. Repeat Finding from Prior Years: No. Recommendation: We recommend that the District implement procedures to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Targeted Airshed Grant Program Federal Financial Assistance Listing Number: 66.956 Federal Grantor: Environmental Protection Agency Award Year: 4/15/2021-4/30/2026; 5/1/2022-4/30/2027 Grant Award Number: TA98T10501; TA98T36001 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the District 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 2024 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 pass-through 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: As a result of our testwork, we noted three (3) out of three (3) instances where there was no evidence that the District verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. However, none of the payments in our sample were made to a suspended or debarred party. Cause: The District did not have policies and procedures in place to verify the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. Effect: The District lacked documentation to support compliance with suspension and debarment requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Suspension and debarment was applicable to 3 subrecipients. We tested all 3 subrecipients during the year. Repeat Finding from Prior Years: No. Recommendation: We recommend that the District implement procedures to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2024-678022-DPI-SB-546, 2024-010014-DPI-NSL-547, 2024-010014-DPISK_NSLAE-566 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria: 2 CFR Section 200.214 of the Uniform Guidance details suspension and debarment requirements for non-federal entities. Condition: One City Schools, Inc. did not document suspension and debarment considerations in accordance with the Uniform Guidance. Questioned costs: None Context: We sampled 2 procurement transactions, noting that none of them had documentation ensuring the vendor was not suspended or debarred. Cause: Policies and procedures were put in place after the prior year single audit findings, but were not able to be incorporated for the current fiscal year under audit. Effect: This could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: We recommend that the Organization establish and maintain effective internal controls over suspension and debarment requirements. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing internal controls over suspension and debarment.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2024-678022-DPI-SB-546, 2024-010014-DPI-NSL-547, 2024-010014-DPISK_NSLAE-566 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria: 2 CFR Section 200.214 of the Uniform Guidance details suspension and debarment requirements for non-federal entities. Condition: One City Schools, Inc. did not document suspension and debarment considerations in accordance with the Uniform Guidance. Questioned costs: None Context: We sampled 2 procurement transactions, noting that none of them had documentation ensuring the vendor was not suspended or debarred. Cause: Policies and procedures were put in place after the prior year single audit findings, but were not able to be incorporated for the current fiscal year under audit. Effect: This could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: We recommend that the Organization establish and maintain effective internal controls over suspension and debarment requirements. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing internal controls over suspension and debarment.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2024-678022-DPI-SB-546, 2024-010014-DPI-NSL-547, 2024-010014-DPISK_NSLAE-566 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria: 2 CFR Section 200.214 of the Uniform Guidance details suspension and debarment requirements for non-federal entities. Condition: One City Schools, Inc. did not document suspension and debarment considerations in accordance with the Uniform Guidance. Questioned costs: None Context: We sampled 2 procurement transactions, noting that none of them had documentation ensuring the vendor was not suspended or debarred. Cause: Policies and procedures were put in place after the prior year single audit findings, but were not able to be incorporated for the current fiscal year under audit. Effect: This could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: We recommend that the Organization establish and maintain effective internal controls over suspension and debarment requirements. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing internal controls over suspension and debarment.
NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The city did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The city does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The city did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The city does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.214 non federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified. Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing. Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not. Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.214 non federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified. Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing. Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not. Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.214 non federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified. Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing. Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not. Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.214 non federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified. Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing. Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not. Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.214 non federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified. Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing. Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not. Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.214 non federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified. Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing. Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not. Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.214 non federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified. Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing. Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not. Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.
Assistance Listing, Federal Agency, and Program Name - 20.507, Department of Transportation, Federal Transit Cluster Federal Award Identification Number and Year - MI-2022-032, MI-2022-048, MI-2020-061 and MI-2018-018 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.214 non federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 specify that when you enter into a covered transaction you must verify that whom you intend to do business with is not excluded or disqualified. Condition - The Authority could not provide evidence that it performed a check to verify all subrecipients were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Authority had 16 subrecipient communities during fiscal year 2024 and could not provide evidence that the check for suspension and debarment was completed prior to entering a subrecipient ageements with two of the communities selected for testing. Cause and Effect - The Authority did not retain evidence to support that they had conducted the search for whether a subrecipient was suspended or debarred prior to entering into a contract. Subsequently, we performed a search of sam.gov to verify that the subrecipients were not suspended or debarred, noting they were not. Recommendation - We recommend the Authority strengthen its controls to ensure documentation is maintained to support that subrecipients are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - SMART is in agreement with this finding. SMART has reviewed and corrected procedures around our suspension and debarment reviews to include all subrecipient award programs. The Manager of Capital Grant Programs will review all subrecipients in new grant awards, and work with the Manager of Transit Asset Management to ensure we have documented our review of subrecipient suspension and debarment.
Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of the Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Fund Federal Award Identification Number and Year SLFRP2024 2001 Pass through Entity Not applicable Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding Yes 2023 002 Criteria Per 2 CFR 200.214 non federal entities are subject to the non procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition The City could not provide evidence that it performed a check to verify vendors or subrecipients were not suspended or debarred. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context During the fiscal year, the City entered into contracts/agreements with 11 contractors and subrecipients. and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract/agreement with them. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs. Cause and Effect The City did not have controls to perform the search for suspended or debarred entities prior to entering into a contract or subrecipient agreement, as a result the City did not comply with the requirements under 2 CFR 214. Recommendation We recommend the City implement controls to ensure that complete the search for whether a contractor/subrecipient is suspended or debarred prior to entering into a contract/agreement with a contractor or subrecipient and retain evidence of the results of the search. Views of Responsible Officials and Corrective Action Plan The City of Port Huron will implement a new process for approval of all invoices related to ARPA grant expenses. This includes a check for suspension and debarment prior to any invoices approval and appropriate documentation.
Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of the Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Fund Federal Award Identification Number and Year SLFRP2024 2001 Pass through Entity Not applicable Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding Yes 2023 002 Criteria Per 2 CFR 200.214 non federal entities are subject to the non procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition The City could not provide evidence that it performed a check to verify vendors or subrecipients were not suspended or debarred. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context During the fiscal year, the City entered into contracts/agreements with 11 contractors and subrecipients. and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract/agreement with them. Subsequently, the City did complete the search on Sam.gov and retained evidence to support that the contractor was not suspended of debarred, thereby creating no questioned costs. Cause and Effect The City did not have controls to perform the search for suspended or debarred entities prior to entering into a contract or subrecipient agreement, as a result the City did not comply with the requirements under 2 CFR 214. Recommendation We recommend the City implement controls to ensure that complete the search for whether a contractor/subrecipient is suspended or debarred prior to entering into a contract/agreement with a contractor or subrecipient and retain evidence of the results of the search. Views of Responsible Officials and Corrective Action Plan The City of Port Huron will implement a new process for approval of all invoices related to ARPA grant expenses. This includes a check for suspension and debarment prior to any invoices approval and appropriate documentation.